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  • Change at the top

    Jeffrey Owens has stepped down as director of the OECD Centre for Tax Policy and Administration. In two exclusive interviews, International Tax Review speaks to Owens and his successor, Pascal Saint-Amans, as the baton of the world’s most important job in tax is passed.

  • Owens looks back on his time in office

    Eleven years after he became the first head of the OECD’s new tax directorate, Jeffrey Owens is leaving the role at a time when tax’s profile in international public policy has never been higher. He talks to International Tax Review about the changes he has seen in international tax cooperation since 2001 and what he thinks is its future.

  • Pascal Saint-Amans finds his stride in Owens’s shoes

    When Jeffrey Owens announced his retirement as head of tax policy and administration at the OECD, the race was on to replace one of the most important figures in global tax affairs. Pascal Saint-Amans is that man and, in an exclusive interview with Salman Shaheen, he discusses his priorities on transparency, transfer pricing and tax avoidance as he takes up his new position this month.


  • Mediation makes ground in resolving disputes

    The UK tax authorities have been trialling mediation as a new way of settling tax disputes. Ralph Cunningham finds out from a taxpayer and an adviser how it could reduce unnecessary time and money spent on litigation.

  • Grand old policies: Republican candidates on corporate tax

    Over the next six months Republicans in each US state will vote for the candidate they want to represent the party in the upcoming November presidential election. With job creation likely to be one issue of central importance come then, the candidates’ tax policies could make or break their campaign. Matthew Gilleard investigates what the hopefuls have to say on corporate taxes.

  • Why taxpayers need their own transfer pricing professionals

    Across the board tax authorities are pushing to collect more revenue and transfer pricing is a prime target. In spite of economic difficulties, transfer pricing specialists are in demand across the world to deal with these extra enquiries and companies are hiring fast. Sophie Ashley looks at transfer pricing recruitment trends and requirements in some of the world’s biggest multinational companies.

  • Copthorne’s legacy: The future of Canada’s GAAR

    Taxpayers awaited the Supreme Court of Canada’s (SCC) verdict in Copthorne with anxious anticipation in December, hoping for a roadmap to help ensure they don’t fall foul of the country’s GAAR. Joe Dalton investigates what the decision means for tax planning and how taxpayers can undertake an action with no business purpose, purely to achieve a tax benefit, without this being seen as an abuse of the Income Tax Act.

  • Private equity transactions in Australia – the new landscape

    Leon Mok, of Baker Tilly Pitcher Partners in Perth, summarises the Australian Taxation Office’s (ATO) views, the context of their evolution and also key considerations for future private equity transactions in Australia.

  • Why the Netherlands implemented a bank tax

    There is strong political feeling resonating around the world that the banking sector must contribute to the recovery from the global financial crisis. With the introduction of a bank tax in the Netherlands from July 2012, Peter Kavelaars of Deloitte analyses the origins of the tax, its scope and design, and potential problems.

  • Sovereign immunity: A US and European view

    With the US recently proposing changes to the regulations under section 892 of the US Internal Revenue Code concerning investment through controlled entities by foreign governments including typical sovereign wealth funds, Peter Blessing and Ansgar Simon of Shearman & Sterling in New York provide an update on the US position and briefly compare the overall approach taken in the US with that taken in the UK, France and Germany.

  • New Zealand taxpayers find feasible option to avoid risk

    A collaborative approach from taxpayers and officials has seen a growth in the popularity of unilateral advance pricing arrangements in New Zealand, explain Mark Loveday and Tanmoy Chakrabarti of Ernst & Young.

  • US revenue’s increased focus on cross-border trade

    As part of a continuing worldwide trend, the US Internal Revenue Service (IRS) is ramping up its efforts to deal with the international tax issues that arise as a result of increased cross-border trade. In the last year, the IRS has realigned its resources, focused attention on strategic issues, and begun to reshape its international tax administration. Barry Shott, Richard Barrett, and Jana Lessne, of PwC US, examine the implications of the IRS competent authority changes.

  • Challenges in financial services transfer pricing in 2012

    The financial services industry seems certain to navigate 2012 through turbulent waters with the eurozone crisis unfolding by the day, the increasingly visible hand of state regulation and bailouts, political sensitivity cumulating in the Occupy Wall Street protests, and the surging influence of the G20 emerging economies in global finance. Sam Sim and Akiko Sumikawa, two financial services transfer pricing specialists, for a leading global bank, say that taxpayers who assume the present trend will continue risk missing some forces already upon us that are shaping the future of financial services transfer pricing (FSTP).

  • The resurrection of France’s carbon tax

    Fighting the greenhouse effect has been a national priority for France for a long time. Sonia Bonnabry of Lexcom looks at how the country is reviving its plans for a carbon tax and learning from past mistakes.

  • VAT debates remain unresolved in the Netherlands

    In the Netherlands two VAT-topics lead to debates with the tax authorities and before the courts, building activities and the treatment of pension funds, explain René van Eldonk and Toon de Ruiter of Simmons & Simmons.

  • Precedent set on statutory mergers and demergers

    The Argentina Supreme Court of Justice has recently issued a significant decision that sheds light on a longstanding and highly debatable issue in the area of tax free reorganisations. Guillermo Teijeiro of Negri & Teijeiro Abogados analyses the conditions that need to be complied with when reorganisations take place within the same economic group.

  • The fine line between planning and avoidance

    Leon Kwong Wing of KhattarWong-Taxand explains how a recent dispute from Singapore sheds light on the debate of a taxpayer’s freedom to legally arrange his affairs in such a manner that maximises his tax benefits against the natural desire of the state to collect the revenue it believes it should.

News Analysis


Tax Relief

  • Tax Relief

    A monthly commentary on the notable facts, ?gures and goings-on in the tax world. Suitable items should be sent to

International Correspondents

International Correspondents