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George Osborne, UK Chancellor of the Exchequer, has delivered the 2013 budget, confirming a one percentage point cut in the corporate tax rate to 20% by April 2015, and claiming the government is building "the most competitive tax system in the world". But there was bad news for banks.

Finland is the latest in a long line of countries to rule on location savings The Finnish Supreme Administrative Court (SCA) rendered a landmark decision on March 4 2013, explains Kennet Pettersson of Ernst & Young. The main dispute concerned location savings and whether such benefits could be allocated to a foreign low cost subsidiary. Though the SCA's decision rejected the locations savings which were sought to be applied in the case at hand, the decision clearly recognises location savings and the allocation of these benefits to a low cost subsidiary provided similar functions were conducted in Finland before the reorganisation and benefits availed can be clearly crystallised. The case concerns a Finnish limited liability company (Company A) which set up a new manufacturing subsidiary in Estonia in 2004. The Estonian subsidiary solely manufactured goods for Company A. Because of this contractual arrangement, the Estonian subsidiary could be regarded as a contract manufacturer. Company A's position in the case was that the savings attained through the lower costs of manufacturing in Estonia should be partly allocated to the Estonian subsidiary. Consequently, the fee charged for goods manufactured by the Estonian subsidiary was based on the manufacturing costs with an added margin including half of the savings that were availed when compared with costs if manufactured in Finland.

Gonzalo Schmidt Gabler Felipe Dominguez Celis The Chilean tax dispute resolution system has always separated the administrative procedure from the judicial procedure; therefore, the taxpayer could design its strategy by deciding when to present its evidence, before the administrative authority or the Tax Tribunal (held by the tax authority), or in both. However, this double instance to produce evidence has suffered an important limitation in the tax dispute process, since on January 27 2009, Act N° 20.322 came into force, which "strengthens and perfects the tax and customs jurisdiction", being one of the most important reforms to the tax justice system administration in Chile.

Heather Gething of Herbert Smith Freehills, and Andrew Silverman of McCarthy Tétrault, look at the operation of the general anti-avoidance rules (GAAR) in the UK and Canada, the reason for their introduction, and how they have been and are likely to be applied.

Gerry Thornton The Irish Finance Bill 2013 published recently contains a number of features designed to bolster Ireland's attractiveness for international companies doing business in and through Ireland. An overview of the most relevant changes is as follows: Ireland was one of the first countries in the world to conclude an inter-governmental agreement with the US in relation to FATCA. The Finance Bill enables the Irish Revenue to make regulations to collect the necessary FATCA information from financial institutions and to exchange such information with the US. These regulations are expected to be published over the coming months.

Chris Hutley-Hurst and Jonathon Egerton-Peters, of Skadden, Arps, Slate, Meagher & Flom (UK), discuss the legality of the EU financial transaction tax (FTT) and explain how taxpayers or member states may seek to challenge it.

Demands on companies for better disclosure of tax information are increasing. Australia is the latest jurisdiction to up the ante by looking to force the release of corporate tax returns. Country-by-country reporting (CBCR) is also gaining more traction (the standard will be imposed on EU banks from 2014). But there appears to be a worrying disconnect in that similar levels of transparency are not being demanded, nor expected, of tax authorities. Matthew Gilleard looks at whether a shift away from the one-sided approach to tax transparency is on the horizon, or whether the “do as I say, not as I do” mantra will continue to apply.

With Russia and France recently announcing they intend to introduce enhanced relationship tax compliance programmes similar to horizontal monitoring in the Netherlands, Joe Dalton asks how successful the practice has been in jurisdictions where it is already in place and how taxpayers might prepare for it in those where it is expected soon.

Nélio B Weiss Philippe Jeffrey A large Brazilian long steel manufacturer has won an administrative-level tax appeal against the Brazilian Federal Revenue (SRF) involving the taxation of profits earned by indirectly controlled foreign corporations. In the yet unpublished decision, the Administrative Court of Federal Tax Appeals (Conselho Administrativo de Recursos Fiscais – CARF) held that the tax authorities had no legal basis on which to tax revenue generated by the foreign entities controlled indirectly through a Spanish holding company. The company underwent a major corporate restructuring in which it contributed shares in a range of its offshore investments to the capital of a Spanish holding company, based in Gran Canaria. This entity became subject to the special ETVE regime (Entidad de Tenencia de Valores Extranjeros), conceded by the Spanish tax authorities. Under this regime, revenues derived from controlled foreign corporations are not taxed in Spain. The Brazil-Spain Double Tax Treaty ensured that profits from the Spanish entity were not taxed in Brazil.

New Zealand taxpayers will be worried the country's general anti-avoidance rule (GAAR) is increasingly being used to effectively re-write deficient legislation and to set aside specific legislation, after the Court of Appeal found against Alesco in a tax avoidance case.