July / August 2014

Main

Transfer pricing risk management: A case for APAs

FATCA finally arrives

KPMG picks Gutman replacement

Robert Jacobson joins Bracewell & Giuliani in Houston

New Baker & McKenzie partners announced

Vitor Gaspar joins IMF as head of fiscal affairs

Skadden counsel nominated to US Tax Court

Wallace joins William Fry

BDO picks Schneider as head of tax in South Africa

Giulia Cipollini joins Withers as head of Italian tax

PLMJ recruits Miguel Reis

Deals of the month

FATCA takes effect and brings in era of continuous compliance

TP adjustment overruled due to taxpayer’s intermediary role

Why Ireland is considered a tax haven

Special features - July / August 2014

One lap to go: BEPS at half time

BEPS and the digital economy: Why is it so taxing to tax?

In search of harmony: Finding a consensus on hybrid mismatches

BEPS scepticism still rife despite OECD’s attempts at reassurance

BEPS and CbCR: A retrapolation five years on

European Tax Awards 2014

What chief financial officers need from their tax directors

Albania: Albanian transfer pricing regulations

Argentina: Case law against minimum notional income tax

Bosnia and Herzegovina: Amended law on tax procedures in Republic of Srpska

Brazil: Provisional Measure No 627 converted into Law

Bulgaria: Bulgaria and the US agree on FATCA implementation

Canada: International employees with stock options

Chile: Proposed taxation on an attributed basis

China: Definition of beneficial owner under entrusted investments

Cyprus: The Cabinet of Cyprus passes Bill for the formation of Unified Single Tax Authority

EU: Hybrid loan arrangements: EU agrees to amend the Parent-Subsidiary Directive

Germany: Global-China cash pooling and transfer pricing implications

Greece: Amendments to withholding tax regime applicable to Greek and foreign affiliated legal entities

Hong Kong: Hong Kong and the source of profits

India: Ruling on seconded employees creating Service PE in India

Italy: Green light given to deductibility of interest expenses for real estate companies involved in the shopping mall business

FYR Macedonia: FYR Macedonia changes tax treatment of uncollected loans

Mexico: Proposed income on hydrocarbons law

New Zealand: Inland Revenue issues rulings on availability of foreign tax credits for tax paid by Australian limited partnerships

Poland: Introducing one of most unorthodox CFC systems in the world? No local capital gains participation exemption

South Korea: Recent developments on the implementation of US FATCA in South Korea

Spain: Spanish government presents tax reform package

Switzerland: Swiss views on BEPS

US Inbound: Anti-inversion Bills and inbound acquisitions

Messi situation for star striker's father

Quotes of the month

Would the real George Bush please stand up?

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

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