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  • The world's leading transactional firms

    Transactions are back. After a few years of hesitancy and a lack of deals, taxpayers have regained confidence and are once again spending cash. As this year's Tax Transactional Survey explains, tax has been an integral aspect of seeing transactions return to the market. International Tax Review highlights which firms are leading the way as the global transaction market stutters back into life.


  • Sam Maruca’s transfer pricing goals may be too ambitious

    When Sam Maruca, the IRS’s first-ever transfer pricing director, spoke to TPWeek in October 2011, he said his aims for his time in office were to improve the organisation’s transfer pricing process. While no one could be accused of disagreeing with his goals, to improve enforcement, resources, skills and to focus on intangibles, transfer pricing practitioners think the new director could be banging his head against a brick wall because of the structure of the IRS. Two lawyers, with IRS experience, tell Sophie Ashley how Maruca’s goals translate into the marketplace.

  • Tax havens seek greater international cooperation

    The worldwide drive against the use of tax havens and opaque banking systems to evade taxation, led by the OECD, has manifested itself in many forms. Andrew Watt, tax investigations consultant, analyses the latest of these forms.

  • Why business has serious concerns about the FTT

    There is continued debate about the pros and cons of a financial transactions tax (FTT). It is a subject which does not want to go away. Writing in a personal capacity, Chris Lenon, who chairs the Tax Committee of the Business and Industry Advisory Committee to the OECD, explains why the tax worries business.

  • Developing tax transparency a decade after Sarbanes-Oxley

    The enactment of the Sarbanes-Oxley Act in the US has led to increased tax transparency and improved risk management. However, Chris Walsh of Vertex claims that the changes have gone too far in favour of the tax authorities.

  • Aon outlines strategy for captive insurance companies

    Noel McNulty of Aon Captive Insurance Managers outlines the possibilities and benefits of the captive insurance industry and how using captive insurers grants companies access to the global reinsurance market.

  • Why the right domicile is key for long term success

    Alfonso Alvarez-Pallete of KPMG provides an insight into the captive insurance industry and argues that choosing the right domicile is vital for long-term success.

  • Lead defence in Canadian case discusses outcome

    Shaun MacIsaac QC, lead litigation counsel for the taxpayer in Alberta Printed Circuits, the most recent Canadian transfer pricing decision, discusses the comparable uncontrolled prices as approved by the tax court.

  • The arm’s-length standard in US and UK transfer pricing rules

    In transactions between related entities across jurisdictions, transfer pricing rules act to allocate profits and losses in a fair and economically justifiable manner to best reflect revenues and costs of each party to the transaction. Bruce Clements and Alan Clements of Clements Law Office discuss the factors in applying the comparability approach in the US and the UK.

  • Intra-group foreign debt in the Canadian resource industry

    The Department of Finance recently released proposed amendments to Canada’s foreign affiliate regime including rules dealing with so-called upstream loans. Bruce Sinclair and Kirsten Kjellander of Blake, Cassels & Graydon explore implications of these proposals for multinational enterprises involved in the natural resource industry.

  • Tax challenges for the energy sector in Indonesia

    Indonesia is blessed with oil, gas, coal and mineral natural resources. The exploitation of energy resources (oil, gas and coal) has contributed significantly in spearheading the growth of the Indonesian economy over the past 40 years. Jul Seventa Tarigan of PB Taxand outlines the challenges taxpayers in the energy sector face and offers an example of how to utilise operations in the resource-rich country.

  • One giant leap for Chinese VAT reform

    On January 1 2012, the Chinese government took a giant step forward in its plan to replace the dual system of indirect taxes – business tax (BT) and VAT– with a single VAT covering both the goods and services sectors. This process started with the commencement of a pilot scheme in Shanghai, explain Lachlan Wolfers of KPMG.

  • Fiscal neutrality – a tool for harmony or disharmony

    Two judgments in UK cases at the European Court promote the principle of fiscal neutrality in VAT matters. However, harmonisation of the rules throughout the EU may not be the result, explains Lutz Koppermann.

  • The Belgian motive test and its application to reorganisations

    In Belgium a common tax planning technique is to convert taxable sale of assets into tax exempt sale of shares through tax neutral reorganisations such as demergers. But with the authorities scrutinising such reorganisations and applying anti-abuse law provisions, Astrid Pieron of Mayer Brown offers advice on how taxpayers can avoid the attention of officials.

  • Modern tax warfare: How to fight the CRA

    After years of maintaining a reactionary stance, the Canada Revenue Agency (CRA) and the Canadian Department of Justice (DOJ) have collectively refocused their efforts to move earlier and more aggressively, thereby redrawing the battle lines as to the manner in which tax disputes are fought. Brandon Siegal and Chia-yi Chua of McCarthy Tétrault explain how to avoid the cross-hairs of the country’s tax officials.

  • What to expect from the Supreme Court in 2012

    Brazil’s Supreme Court has never issued a final ruling on a tax matter. Glaucia Maria Lauletta Frascino of Mattos Filho, Veiga Filho, Marrey Jr e Quiroga Advogados predicts that 2012 will be the year for this fact to change and argues which case is likely to be the first.

  • Opportunities in value chain transformation

    The globalisation of trade and commerce has led to value being added in different quarters of the world as intermediates get transformed into finished products or services while being delivered to customers. There is now a growing need to synchronise these operations to make value chains more effective. Rakesh Mishra and Suchint Majmudar of PwC explain why this shift ought to put the business at the centre of the change and deal with advantages of value chain transformation.

News Analysis


Tax Relief

  • Tax Relief

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

International Correspondents

International Correspondents