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PwC has just hired a well-connected tax specialist in London to spearhead its work with governments to improve how tax authorities operate

Richard Stephens International law firm Watson, Farley & Williams has promoted one of its London tax lawyers, Richard Stephens, to partner.

Malaysia’s taxpayers are now likely to use Hong Kong as a gateway to investments in China Hong Kong and Malaysia have entered into a new double taxation agreement (DTA), pending ratification, with provisions to clarify that a tax liability on business profits only arises if the company has a permanent establishment (PE) in the other jurisdiction, as well as reducing withholding tax rates and increasing investment opportunities.

Last June, International Tax Review looked at the concept of joint auditing while the mechanism was still in its infancy. One year on, Matthew Gilleard assesses how things have progressed and if we have any clearer idea of whether the process works in reality.

US taxpayers breathed a collective sigh of relief in April when the Supreme Court delivered its verdict in Home Concrete which stated that the Internal Revenue Service (IRS) was not permitted to use an extended six-year statute of limitations period to investigate overstatements of basis. But there was a broader issue at stake in the case – the IRS’s ability to issue regulations and apply them retroactively. Joe Dalton explores the wider implications of Home Concrete and why US taxpayers will be hopeful the ruling will diminish the IRS’s arsenal in avoidance cases.

Jack Grocott speaks to Watson Wang, SABIC’s new head of Asia-Pacific tax, about the role of a tax director in China, how to create certainty and to manage effectively a working relationship with the increasingly aggressive tax officials.

The 2012 International Tax Review Asia Tax Forum, held in Singapore, once again attracted scores of tax professionals from throughout the Asia-Pacific region and beyond. While transfer pricing was high on the agenda, it was not the only concern and other panels included: keeping in step with Chinese rules changes; establishing trust between officials and taxpayers; dealing with developing tax systems; the Indian reform; cross-border issues; dispute resolution; improving effectiveness in the tax department through technology; and indirect tax.

Luiz Felipe Centeno Ferraz, Alessandro Amadeu da Fonseca and Antonio Carlos Marchetti Guzman of Mattos Filho Veiga Filho Marrey Jr e Quiroga Advogados analyse the recently updated Brazilian transfer pricing rules and offer insight into what it means for multinational taxpayers.

Ian Farmer The Australian government has released an exposure draft (ED) of the first of two stages of reforms to the Australian transfer pricing rules. The ED proposes to introduce new rules that will apply retrospectively from 2004 to give the Commissioner an additional power to impose tax where a taxpayer engages in dealings that may be subject to a double tax treaty.

Soraya Jamal