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  • After 20 years, Canada’s Supreme Court has finally made a decision on the GlaxoSmithKline case. The litigation is not yet over, however. Dale Hill, Mark Kirkey & Pierre Alary of Gowlings – Taxand explain why.
  • The conversion to international financial reporting standards (IFRS) is anticipated by many global companies, and many have already implemented, or are in the process of implementing, the new standards for statutory purposes. As companies continue to adopt the new principles, their tax departments and transfer pricing practitioners will be expected to maintain seamless continuity in demonstrating that intercompany transactions are priced in accordance with the arm’s-length principle (or are priced as if the transactions had taken place between third parties). For many companies, this has started to cause transfer pricing concerns. Kristine Riisberg, Deborah Keisner, and Todd Wolosoff, of Deloitte Tax, New York, explain why.
  • International Tax Review and TPWeek hosted the 12th annual Global Transfer Pricing Forum in Paris in September.
  • The financial transaction tax (FTT) is set to be introduced by 11 EU member states. Richard Murphy of Tax Research looks at the case for an FTT, how it would work in practice and why, contrary to other anti-poverty campaigners, he believes it should not be used to raise revenue for developing countries, but to constrain out of control banking.
  • Dajana Topic, Eurofast Global Under article 14 paragraph 3 Law of the Republika Srpska (RS) budget execution for 2012 ( Official Gazette of the RS, No. 3/12) and the regulation on conditions and implementation of programmes to support investment and employment (Official Gazette of the RS No. 70/12), Ministry of Finance of the RS published a public notice "grant funding for implementation programmes to support investment and employment". Subject to the public notice is the registration of investment projects in the manufacturing sector (new investments in fixed assets), which provides for the hiring of new employees, in the territory of the RS.
  • The Delhi High Court recently decided a case in favour of global telecommunications company Nokia. Ravishankar Raghavan, of Majmudar & Partners, explains why the judgment should reassure foreign investors that benefits provided under tax treaties will not be overridden by the Indian government’s retrospective amendments.
  • Rudina Hoxha, Eurofast Global The new excise law that defines the general rules on manufacturing, holding, storage, movement and control of excise goods entered into force on October 1 2012. The new law also sets specific rules on excise duties applied to the consumption of energy products, alcohol and alcoholic beverages, tobacco and its by-products. At the same time, administration and regulation of custom and excise duties has been transfered from the Albanian General Tax Directorate (GTD) to the Albanian Customs Administration (ACA).
  • Nélio Weiss and Philippe Jeffrey, PwC The Brazilian government issued Law 12,715, on September 18, a conversion of the Provisional Measure (PM) 563 issued in April 2012, introducing changes to Brazilian transfer pricing regulations. Important changes included in the law as compared to the original text of the PM are:
  • Laysym Sim, VDB Loi In a major practical simplification of the tax filing process, the Cambodian tax authorities have instructed tax offices to allow taxpayers to file monthly and annual tax returns without using the hard copy forms that these offices make available. To date, each office issues a form that is stamped for that individual tax office. As a general rule, taxpayers are required to use that particular form for filing taxes in that office.
  • Unless it changes, the plan to introduce a general anti-abuse rule in the UK will only extend the powers of the tax authorities, believes Julie Carine Leblanc-Leduc of King’s College London