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  • The tax department of the future

    The demands on a multinational company’s tax department are growing quickly as tax authorities communicate more with one another and global compliance requirements increase. Joe Dalton discovers how the structure of tax departments is evolving to deal with these demands and what the tax function of the future may look like.


  • Bringing a different perspective to the OECD

    The OECD’s Centre for Tax Policy and Administration (CPTA) faced an uncertain future last year when three of its high-level officials left. The candidates that have taken on the task of directing tax and transfer pricing policy have brought with them an air of calm, however, that has settled the turbulent waters at a crucial time for transfer pricing policy with their boundless enthusiasm and experience. Sophie Ashley speaks to Marlies de Ruiter, the new head of the Tax Treaties, Transfer Pricing and Financial Transactions division in her first month on the job.

  • The challenges and opportunities of interim VAT management

    Suddenly finding yourself without a key part of your tax department can be a problem at the best of times, particularly in the middle of a major international merger. Salman Shaheen explores how taxpayers can benefit from interim VAT management in emergency situations and how it differs from companies’ more common experience of secondment.

  • Latin American advisers appraise the region’s officials

    The interactions between taxpayers and officials in Latin America can often be fiery, but continual efforts are being made to improve such relationships. Matthew Gilleard speaks to advisers from across the region to gauge how things are progressing and whether the officials are doing enough.

  • Commission goes after double non-taxation

    Back in January, the European Commission launched a public consultation on the double non-taxation of cross-border companies. The Commission hopes the consultation will gauge the full scale of the problem and see where the main weaknesses lie and will develop a policy response before the end of 2012. Jack Grocott speaks to Philip Kermode, Director for Direct Taxation in DG Taxation and Customs, about what he hopes the consultation will achieve and what it means for taxpayers.

  • Global depositary notes to finance companies in Mexico

    José Carlos Silva and Eduardo García Ruiz of Chevez, Ruiz, Zamarripa y Cia outline the opportunities available to taxpayers when using global depositary notes (GDNs) in Mexico.

  • Treatment of goodwill paid on acquiring a Brazilian company

    The adoption of new accounting standards based on IFRS as of 2008, and the effects of such new rules for Brazilian taxpayers, is among the most relevant tax matters under discussion in Brazil, explain Paulo Rogerio Sehn and Simone Dias Musa of Trench, Rossi e Watanabe Advogados.

  • Why tax competition in Asia-Pacific will only get stronger

    Jurisdictions such as India, Hong Kong and Singapore have used tax policy to compete for foreign direct investment. Josephine Chuk explains why other countries in the Asia-Pacific region are likely to follow their example.

  • Navigating permanent establishment in India

    The OECD published a discussion draft on the future of permanent establishments (PE). Pallavi Bakhru & Nidhi Gupta of Walker, Chandiok & Co provide an insight into the Indian perspective and use examples on how the country interprets the definition of PE.

  • The new transfer pricing era in Indonesia

    For the past three years, Indonesian taxpayers have been facing more challenges from the Directorate General of Taxes (DGT) regarding their related-party transactions. The areas of dispute are various; common challenges from the DGT are on management service fees, cost allocation, royalty fees, purchases of raw materials, sales of goods, and sales of capital goods. Permana Adi Saputra, of PB Taxand, describes the new regulations and how they will affect taxpayers.

  • Hong Kong to launch APA programme

    Hong Kong’s Commissioner of Inland Revenue (CIR) announced during a public seminar in February 2012 that the Inland Revenue Department (IRD) is preparing to launch an advance pricing arrangement (APA) programme starting in April 2012. Philip Wong and Petrina Chang of Deloitte in Hong Kong provide a break-down of the new facility.

  • Price level indexes and intra-group service charges

    When allocating corporate costs for intra-group services, the Norwegian Tax Authorities has in recent years been claiming that allocations based on opex/capex must be adjusted for local price- and cost levels by applying a price level indicator (PLI). Jan Jansen and Joachim Bjerke of BA-HR explain what this means for the Norwegian energy sector.

  • Clean energy sector tax incentives in the US and UK

    Tax incentives have long been key in the establishment and development of alternative energy. Lawyers from Shearman & Sterling in London and New York compare how the UK and US governments use incentives to encourage investment and explain why many of these incentives may not be around for much longer.

  • Financial transaction tax set to fall short of objectives

    A financial transaction tax seems certain to be introduced, if not across the EU, then in individual member states. However, Philip Martin, formerly co-head of tax at Nomura, does not believe it will raise the revenue envisioned by its designers or lead to more market stability.

  • How South Africa’s proposed carbon tax will affect business

    South African companies are making sound progress as they prepare for a new carbon tax, by improving energy efficiency and monitoring and reporting emission levels. However, the legacy effect of substantial coal-based infrastructure is hindering the transition to alternative, renewable energy sources, finds Catherine Lewis of KPMG.

  • Investors in US equity derivatives face wider withholding tax net

    Recent guidance provides temporary relief to non-US persons that invest in US equity derivatives, but proposed rules may lead to some harsh consequences, warn Julio Castro and Taylor Romigh of Dewey & LeBoeuf.

  • The Supreme Court’s first-ever GAAR decision

    Emer Hunt and Turlough Galvin of Matheson Ormsby Prentice analyse Ireland’s first-ever GAAR case to be heard at the Supreme Court and explain why the ruling creates uncertainty for future transactions.

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