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  • 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.
  • Heiko Penndorf is rejoining Ashurst as a partner in its Frankfurt office. He was formerly an associate of the firm before joining Mayer Brown, where he was a partner. An associate is also moving to Ashurst with him.
  • Chidambaram: I need time to look at DTC. It requires a fresh look
  • A new paper from the MIT Global Change Institute, a Bill before Congress and a Bloomberg editorial have all increased demand for a carbon tax in the US.
  • Cédric Tussiot and Joachim Bailly look at intermediation in the sale of shares of real estate companies in Luxembourg and whether VAT should be applied, based on the recent European Court of Justice case for broker firm DTZ Zadelhoff vof.
  • To route their investments in a tax efficient manner, investors in the EU often use special purpose vehicles (SPV) incorporated in a third-party jurisdiction. The preferred jurisdictions are generally Luxembourg, the Netherlands, and, to a lesser extent, the UK or Switzerland (which benefits from certain EU directive rules under EU-Swiss agreements). Antoine Vergnat of McDermott Will & Emery in Paris provides a practical description of the main substance-related requirements that SPVs must satisfy to benefit from exemptions or reductions of withholding taxes on portfolio incomes derived from EU operating companies (which assets are not predominantly made up of real estate assets).
  • The OECD released a number of reports relating to transfer pricing recently. The draft on intangible assets was released ahead of schedule in June, but the organisation has also produced a draft on safe harbours and memorandums of understanding and another on timing issues. Sophie Ashley considers the practical implications of these reports.
  • 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.