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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.

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

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.

Officials claim that increased transparency in tax disputes reduces exposure to long and costly battles. But disclosing sensitive information to revenue-hungry officials can be detrimental to a business’s bottom line. Jack Grocott speaks to advisers from across the world to discover when is the best time to be transparent in a dispute.

Once a fringe idea for a new accounting standard, country-by-country reporting now fits the mood of a public eager to lift the lid on corporate secrecy and is fast gaining credence with policy makers and regulators. Salman Shaheen finds out what it is, what it means for taxpayers and why the tax justice movement believes it is the panacea for tax evasion and secrecy.

Monica Bhatia is the head of the secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes at the OECD. Having worked as a tax administrator and policy maker in an emerging economy, Bhatia understands the different requirements developing countries have when it comes to transparency in tax administration and is able to translate this into practical advice for the Global Forum’s members. She talks to Sophie Ashley about the work the forum is doing to promote tax transparency and exchange of information in a rapidly changing environment.

Bob Diamond was forced out of his role as chief executive of Barclays in the wake of a series of banking scandals including the deceptive altering of the London interbank offered rate (Libor interest rate). In the age of scandals and public enquiries, the desire to know more about companies’ activities, including their tax policies and compliance, is increasing from a variety of perspectives, explains Matthew Gilleard.

Marcelo Laport

British Airways fears retaliatory action against EU airlines

Dirk Van Stappen The Belgian federal government has approved a new draft programme law at its meeting of May 11 2012 which has been submitted to parliament on May 15 2012. The draft law modifies the recently approved thin capitalisation rule to ease its negative consequences for treasury centres in Belgium. According to the thin capitalisation rules as foreseen in article 198, 11° of the Belgium Income Tax Code as recently changed by the Programme Law of March 29 2012 (published in the Belgian Official Gazette on April 6 2012), the deduction of interest paid on loans will be disallowed in case, and to the extent of the excess, the total amount of these loans is higher than five times the sum of the taxed reserves at the beginning of the taxable period and the paid-up capital at the end of this period.