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  • Rossitza Koleva, Eurofast Global Amendments to the Law on Excise Duties & Tax Warehouses, and to the VAT Law for the recording and reporting of sales in points of sale with fiscal devices entered into force on July 17 2012.
  • Hans-Martin Eckstein, PwC In an unusually rapid reaction, the finance ministry has included provisions in its Annual Tax Bill 2013 to adopt the "authorised OECD approach" to the taxable income of permanent establishments (PEs). This approach was formulated by the OECD in its PE report of July 22 2010 calling for internationally uniform PE taxation on the basis of equal treatment of branches, subsidiaries and partnerships. Fundamentally, each should establish its taxable income as though it were an independent legal entity trading at arm's-length with all related parties and fellow business units.
  • Chizuko Tomita, Morrison & Foerster The absence of specific Japanese rules on the treatment of a foreign subsidiary's reorganisation has sometimes hindered Japanese companies when trying to conduct reorganisations of their foreign subsidiaries for valid business purposes. Often, Japanese companies have had to approach the Japan National Tax Agency (NTA) in advance to obtain certainty on their tax treatment.
  • KPMG has hired Chetan Vagholkar as a partner in the International Corporate Services practice.
  • Andrew Watt Rebecca Busfield The former leaders of Taxand UK's tax investigation team have established a new consultancy service, Watt Busfield Tax Investigations, to help UK taxpayers take full advantage of voluntary disclosure opportunities provided by HMRC. Andrew Watt and Rebecca Busfield will lead the practice, which aims to assist taxpayers in making voluntary disclosures, or full disclosures when they have already been challenged by HMRC, in a bid to avoid tax litigation.
  • Deloitte has added to its team in Wales by hiring Rhianne Cox as a director in its tax service line. She will be based in Cardiff.
  • Israel has introduced a number of indirect tax changes recently. Tal Hamdi of Herzog Fox & Neeman looks at where they are going.
  • The last 12 months have seen a surge in the use of retrospective amendments by governments around the world, all aimed at recouping extra revenue from taxpayers. Matthew Gilleard assesses the issues thrown up by lawmakers going back in time, and whether this worrying trend for taxpayers is set to continue.
  • UBS paid the price for ignoring a whistleblower
  • 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.