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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.

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.

The exchange of taxpayers’ information between revenue authorities has come a long way in the past decade. The idea that more than 100 countries would have signed up to information exchange on request agreements seemed fanciful even three years ago. But now another, more comprehensive exchange model is coming to the fore. Joe Dalton looks at the rise of automatic information exchange and what it will mean for taxpayers.

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.

Marcelo Laport

Rafael Calvo In its rulings dated April 13 2011 and April 26 2012, the Central Economic Administrative Tribunal (Tribunal Económico-Administrativo Central or TEAC, belonging to the Ministry of Finance) concluded that, contrary to the view taken by the taxpayers, the juros sobre o capital próprio (JSCP) distributed by Brazilian subsidiaries should not qualify in Spain for the exemption granted to dividends and shares in income under the Spanish Corporate Income Tax Law. According to Brazilian Law, JSCP result from applying an interest rate over the equity of the company and are distributed to the shareholders out of the profits of the company and pro rata to their holdings in the capital.

Khoonming Ho

Adrian Rus As expected, Romanian tax authorities' attention on transfer pricing matters is continuously increasing and our experience reveals that in the last year they are increasingly scrutinising the related party transactions of multinationals, requesting transfer pricing documentation reposts as part of various tax audits (audits focused on corporate income tax or VAT). Hence, for the tax directors of multinationals operating in Romania, preparation on transfer pricing documentation matters should represent a key aspect on their agenda much more than two to three years ago.

Sead Dado Salkovic In Montenegro transfer pricing regulations are included in the Corporate Income Tax Law (CITL) and are in line with the arm's-length principle. In line with the aforementioned, transfer pricing is considered to be the price applied in relations to transactions between related parties. Related parties are considered to be the parties with special relations that may have direct impact on the conditions or economic outcomes of transactions among such parties.