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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.

Jean Marc Gagnon and Emmanuel Sala, Blake Cassels & Graydon For non-resident employers hiring employees performing services in Canada, or abroad but residing in Canada, it may be easier to rely on general public information provided by the Canada Revenue Agency (CRA) (through their website or otherwise) to determine whether Canadian federal payroll withholding tax obligations exist. This may not always be reliable advice. The CRA has been requested to confirm whether information provided through a government website was accurate and complete for non-resident employers' Canadian federal payroll withholding income tax (Payroll Withholding) obligations. The CRA confirmed that the information could be misleading in that it may imply that non-resident employers have Payroll Withholding obligations only if the employees provide services in Canada. This information was therefore not accurate.

Charlotte Rushton, managing director Asia Pacific EMEA for the tax & accounting business of Thomson Reuters, considers the challenges facing corporate tax departments in India after the recent third annual India Tax Forum.

Type of Agreement Country Country Date Signed Link Tax Information Exchange Agreement Brazil UK September 28 2012 Double Taxation Avoidance Agreement Finland Tajikistan October 24 2012

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.