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Boris Lazic On May 22 2012, Cyprus and Austria signed a protocol amending the Convention for the Avoidance of Double Taxation (DTT) between the Republic of Austria and the Republic of Cyprus with respect to taxes on income and capital, which was signed in Vienna on March 20 1990. The protocol amends Article 26 of the DTT relating to the exchange of information. In accordance with the Protocol, the contracting states shall exchange such information as is foreseeably relevant for the purpose of carrying out the provisions of the DTT between Austria and Cyprus.

Michael Shikuma

Janne Juusela The merger between A Ltd and B Ltd was registered to the Finnish National Board of Patents and Registration in 2008. B Ltd had verified tax losses from previous accounting periods. A merger consideration was paid in cash to the sole shareholder of B Ltd. The local tax office stated that the merger was not in accordance with the Finnish legislation concerning transfer of losses. They considered that the merger met the requirements of the Income Tax Act but did not comply with conditions of the Business Income Tax Act. Tax officials interpreted that B Ltd was dissolved and thus the losses did not transfer to A Ltd.

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:

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.

Rolf Winand has joined DFDL Mekong as a partner in the tax and customs practice group. His role will mean he is responsible for the jurisdictions of Cambodia and Vietnam.

Richard Allen, co-founder of Retailers Against VAT Avoidance Schemes (RAVAS) and former head of Delerium Records, looks at how Low Value Consignment Relief (LVCR) has undermined the single market.

Location saving is a hot issue in developing countries. Yin Chao, who speacialises in transfer pricing at Siemens in China, and Yin Shuping, who is an associate professor at Guangdong Polytechnique Normal University, explain China’s perspective on the transfer pricing aspects of location saving on contract R&D.

Javier Martín Martín and Diana Garrido Hernando of Ernst & Young look at indirect tax as a way out of Spain’s dire economic situation.

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.