September 2012

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Olin chooses Alvarez & Marsal Taxand

New director at ENS South Africa

New venture for Teijeiro

Baker & McKenzie promotes nine to partnership

HMRC announces Hartnett’s replacement

VDB Loi expands in Southeast Asia

Stibbe promotes two to partnership

Land leaves Linklaters to set up new tax practice

Andrews to lead Deloitte’s tax management consulting group

Musat & Asociatii adds to tax practice

Beswick steps into Kroeker’s shoes at SEC

Crowell & Moring adds two to Washington office

Amarchand hires ex-KPMG partner as head of tax

HMRC hires Granger for enforcement and compliance role

Annette Ahlers is new Moss Adams partner

Deals table

Misreported losses by Finnish parliament shows inexperience

Why France’s FTT will be short lived

Australia commits to improve alternative dispute resolution

UK updates CFC excluded territories exemption

Africa: M&A challenges faced by foreign investors

Spain hikes taxes to battle downturn

No waiting – FFIs should act now to prepare for FATCA

Australia to reform its general anti-avoidance regime

The UK GAAR: What needs answering

Building your BRICS tax strategy

The future for BRICS tax policy coordination

Practical transfer pricing in the BRICS

Structuring your tax affairs in the BRICS

A foreign investor’s tax guide to the CIVETs

FATCA – How ready are you?

Canada – US arbitration: Too soon to pass judgment

Analysing the OECD draft on intangibles

Myanmar’s tax on non-residents on the eve of a leap in FDI

Navigating India’s proposed GAAR

Increased focus on tax governance

Transfer pricing investigation versus self-inspection

The future of indirect taxes in Japan

Outsourcing – A solution to VAT compliance challenges

Taxation of corporate debt in Ireland versus the UK

Beneficial ownership of Danish deemed dividend distributions

Opinion in FII litigation fails to answer all questions

Poland challenges related entity transactions

Introduction of new measures to tackle VAT fraud

Albania: Income and capital tax treaty in force

Argentina: Argentina terminates tax treaties with Chile and Spain

Belgium: Belgium’s recovery plan includes few tax measures

Bosnia and Herzegovina: Bosnia and Herzegovina ratifies tax treaty on income and capital with Kuwait

Brazil: Superior Court determines WHT exemption on remittance of service fees

Bulgaria: Amendments to the law on statistics of intra-community trading of goods

Canada: Draft legislation on foreign affiliate dumping rules

China: Tax treaty beneficial ownership clarifications issued

Cyprus: The jurisdiction of choice for intellectual property rights

European Union: New EC proposals on tax havens, aggressive tax planning, tax fraud and tax evasion to be presented in Q4 2012

Finland: Court ruling on back-and-forth stock trading

France: Significant changes further to the amended Finance Act for 2012

Germany: Return delays of self-assessed and withholding taxes to be pursued more rigorously

Hong Kong: Hong Kong update

Hungary: Hungary to introduce FTT

India: Draft guidelines on GAAR

Ireland: Ireland enhances its leasing regime

Japan: Introduction of reporting requirement of overseas assets

FYR Macedonia: Changes in the law on tax procedure

Mexico: Treaty between Mexico and Hong Kong

Montenegro: Tax credits – avoidance of double taxation

Romania: VAT deduction limitation for vehicles and related expenditure

Serbia: Bilateral relations with Turkey

South Africa: Changes to taxation of interest payments

Spain: Favourable judgment on the doctrine of estoppel

Turkey: An opportunity for regional management centres to operate in Turkey under a liaison office structure

US Inbound: Debt equity characterisation

US Outbound: IRS finalises section 1248 regulations on cross-border distributions

Tax relief

Poland: Less formalities to apply zero VAT rate on exports

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