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Stephan Eilers and Alexander Schwahn of Freshfields Bruckhaus Deringer provide a brief overview of a classic structure for a private equity investment in Germany, and they critically analyse the efforts of both the tax authorities and the legislature to place restrictions on debt push-down structures.

Irish section 110 finance companies now commonly feature in international finance structures. Over the years their use has expanded from being the issuing vehicle in more traditional securitisation and repackaging type transactions, to a broader range of applications, such as being the issuers of Islamic finance instruments, distressed debt acquiring companies, the underlying vehicle for US life settlement funds, and, more recently as aircraft leasing companies. James Somerville of A&L Goodbody explores this trend in light of recent guidance.

Sean Foley

The days of European nations playing policeman to the world are long since gone. Nevertheless, EU policy is sparking protests in the far-flung corners of the globe and few more so than its decision to bring airlines into the emissions trading scheme.

Jeffrey Owens, the former OECD tax chief, has joined Ernst & Young as senior tax policy adviser to Dave Holtze, the firm's global vice-chair of tax.

The Australian Treasury is working through its guidance on permanent establishments. Paul Balkus and Melissa Heath of Ernst & Young discuss the background, issues and expected Treasury approach in relation to the third tranche of the re-write dealing with the attribution rules to PEs.

The argument for tax transparency has never been stronger and legislation is on its way. In a special issue of International Tax Review, we lay bare country-by-country reporting, information exchange, corporate social responsibility and exposure to risk to find out what transparency means for you. Plus an interview with the OECD’s Monica Bhatia.

Stefan Ditsch Following an attack by the European Commission, Germany has modified its anti-treaty, anti-directive shopping rule for 2012. On January 25, 2012 the finance ministry revised its interpretive decree accordingly. Officially, the government's intention was to move from the previous all or nothing approach to an apportionment scheme limiting treaty entitlement to reduced withholding tax to the level indicated by the clear absence of abuse. The new rule is: A withholding tax reduction will only be granted to the extent that:

Kevin Downing, one of the key prosecutors in the US government's fight against offshore tax evasion, has become a member of Miller & Chevalier. Since 2004, he has been senior litigation counsel with the Department of Justice's Tax Division, which he joined 15 years ago.

Deloitte has hired Jonathan Traub, former staff director for the Committee on Ways and Means of the US House of Representatives, for its Washington National Tax practice.