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Flick Gocke Schaumburg has appointed four new equity partners in its tax practice.

Janusz Fiszer has joined PwC in Poland, becoming a partner in the integrated tax and legal practice.

Ken Harvey returns to the US after a three year secondment with KPMG China, where he was based in Hong Kong and supported the US tax practice for the Asia Pacific region. His role in Asia involved providing US corporate tax advice for China-based outbound investors and US-based multinationals operating in the Asia Pacific region.

Wiwin Siswanti, PB Taxand The Indonesian Tax Office (ITO) has recently been actively conducting transfer pricing audits on multinational companies since many of these companies have been reporting tax losses for a consecutive three to five fiscal years. There are also other criteria that may trigger the tax audit giving the ITO an opportunity to review the implementation of the arm's-length principle on controlled transactions such as payment of tax that is considered low by the ITO, significant volume and amount of transactions with related parties, the ITO's perception that the taxpayer has been carrying out business not in accordance with the general practices, and a lack of appropriate documentation. The ITO has also issued guidance for taxpayers and tax offices to implement the arm's-length principle on related party transactions in 2010 (as stated in Director General of Taxes (DGT) Regulation Number PER-43/PJ/2010, which was then amended by DGT Regulation Number PER-32/PJ/2011). The significant provisions in said regulation are: the new safe harbour of IDR10 billion ($1.1 million) for total transaction per year for each related party and the use of appropriate transfer pricing method, instead of the hierarchy basis with comparable uncontrolled price method (CUP) as the primary method.

Sabine Graziosi, KPMG A second series of tax measures announced in the government agreement of December 1 2011 is included in a new draft program law. The most important measures affecting companies deal with the conditions of the exemption of capital gains on shares, the extension of thin capitalisation rules and a complete rewriting of the general anti-abuse measure.

Bob van der Made, PwC On February 2 2012, in a surprise announcement at the first high-level European Competition Forum in Brussels, EU Competition Commissioner Joaquín Almunia announced that the Commission will overhaul the EU state aid control process. The move is part of the EU's comprehensive strategy to exit the financial, economic and sovereign debt crises by focusing on better use of public finances and reinvigorating the internal market. Selective tax advantages are mentioned as one of the top three priority areas for action in the area of state aid by the EC, together with "subsidised network industries and publicly supported incumbents in liberalised markets" due to their distortive effect on intra-EU competition.

The imposition of harsh penalties against General Electric (GE) provides a stark warning to companies using tax shelters in the US.

Two judgments in UK cases at the European Court promote the principle of fiscal neutrality in VAT matters. However, harmonisation of the rules throughout the EU may not be the result, explains Lutz Koppermann.

The enactment of the Sarbanes-Oxley Act in the US has led to increased tax transparency and improved risk management. However, Chris Walsh of Vertex claims that the changes have gone too far in favour of the tax authorities.

The State Administration of Taxation (SAT) in China has provided an overview of anti-avoidance initiatives.