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A monthly commentary on the notable facts, figures and goings-on in the tax world.

Thuan Pham In an effort to avoid the double taxation of international income and thus promote foreign direct investment, Vietnam has concluded double taxation agreements (DTAs) with more than 60 countries to date. Vietnam has also issued a number of circulars providing guidelines for implementing and interpreting these DTAs. Most of the circulars were issued between 1997 and 2000. In 2004, Circular 133, a comprehensive circular covering all articles of the tax treaties in detail, was issued. The Ministry of Finance (MOF) is now planning to replace Circular 133. A draft is in process and is at the stage of receiving public opinions.

David McNeil

Wayne Swan has been replaced by Chris Bowen as Australia’s Treasurer, or finance minister. Swan resigned yesterday after prime minister Julia Gillard was defeated by Kevin Rudd for the Labor Party leadership.

The tax director of a Canadian multinational shares his experiences of the Canada Revenue Agency’s (CRA) new risk-based approach to audits and offers some advice to other taxpayers going through the process.

Multinationals that enter into cooperative compliance arrangements with revenue authorities can cut their risk of becoming involved in tax disputes, according to taxpayer and revenue authority representatives speaking at Oxford University yesterday.

The Royal Court of Jersey has denied an attempt by Volaw Trust and Corporate Services (Volaw) to block an information exchange request by a Norwegian taxpayer. It is the British Crown Dependency’s first ever appeal over a request made via a tax information exchange agreement (TIEA).

The most senior members of the Senate Finance Committee in the US have called on other senators to send them their proposals, by the end of July, for tax expenditures to add back and improve a reformed tax code.

Transfer pricing regimes in Asia are developing quickly. With India’s advance pricing agreement programme, a growing culture for dispute in China and changes to Indonesia’s legislation, to name but a few recent developments, it is important taxpayers keep themselves up to date with best practice.

A few decisions taken in recent years by the Italian Courts have shed some light on the allocation of the burden of proof in transfer pricing disputes. Piergiorgio Valente, Managing Partner of Valente Associati GEB Partners explains how.