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UBS paid the price for ignoring a whistleblower

Multinationals are clambering over one another to try to establish themselves in Brazil, confident of the rich rewards such investment could reap while the country continues to harbour one of the world’s fastest growing economies. But how is Brazil’s tax administration coping with this changing business landscape? In an exclusive interview, Joe Dalton speaks with Monica Calijuri, Commissioner of the Federal Revenue of Brazil’s Large Business Office in São Paulo, to find out what part the tax authorities are playing in bringing more investment to Brazil.

The Indian transfer pricing regulations are expected to provide a more robust framework for taxpayers and the revenue authorities alike to demonstrate the arm’s-length character of their related-party transactions. However, Amit Agarwal of Ernst & Young argues that the wide discretion conferred on the revenue authorities in the interpretation and implementation of these regulations has spawned a cesspool of tax controversies leading to substantial tax adjustments. It is reported that in the latest round of transfer pricing audits the cumulative value of these adjustments was $8.9 billion.

A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com

Antonio Tomassini and Alessandro Martinelli, of DLA Piper, analyse a recent Italian circular which gives clarity on mutual agreement procedures (MAP) and look at how its guidelines will interact with domestic law.

Steve Mendelsohn, managing director of Knowledge Solutions for the Tax & Accounting business of Thomson Reuters, looks at how the technology revolution is helping corporate tax professionals access better organised and more structured information for informed decision making.

The Australian Government has announced the appointment of Geoff Leeper as a full-time Second Commissioner to the Australian Taxation Office (ATO).

Jayne Newton Jayne Newton has been appointed as tax investigations director at DLA Piper, within the firm's litigation and regulatory group. She makes the move from Lloyds Banking Group, where she was head of operational and employee taxes, having been with the company for 21 years.

HM Revenue & Customs (HMRC) has collected more than £1 billion ($1.6 billion) in transfer pricing yield between March 2011 and 2012. Tax practitioners hope the high figure means more resources for the authority's advance pricing agreements (APA) programme. Statistics also show that, since March 2010, the age of open enquiries has reduced, as has the age of settled enquiries.

Pawel Szymanski, MDDP Poland introduced a worldwide taxation system for its residents. Non-resident individuals are, in general, subject to income tax in Poland only to the extent of income from sources within the country.