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Sarkozy is determined to introduce a FTT, with or without Europe joining in

Taxpayers will need to be more careful if the rule is implemented The outline for Japanese tax reform proposals was released on December 26 2011 with changes to intercompany loan regulations.

The financial services industry seems certain to navigate 2012 through turbulent waters with the eurozone crisis unfolding by the day, the increasingly visible hand of state regulation and bailouts, political sensitivity cumulating in the Occupy Wall Street protests, and the surging influence of the G20 emerging economies in global finance. Sam Sim and Akiko Sumikawa, two financial services transfer pricing specialists, for a leading global bank, say that taxpayers who assume the present trend will continue risk missing some forces already upon us that are shaping the future of financial services transfer pricing (FSTP).

The APA programme will launch in April The Hong Kong Inland Revenue Department (IRD) will launch an advance pricing agreement (APA) programme in April.

Eleven years after he became the first head of the OECD’s new tax directorate, Jeffrey Owens is leaving the role at a time when tax’s profile in international public policy has never been higher. He talks to International Tax Review about the changes he has seen in international tax cooperation since 2001 and what he thinks is its future.

A lack of compliance is the reason behind the increased tax gap

Leon Mok, of Baker Tilly Pitcher Partners in Perth, summarises the Australian Taxation Office’s (ATO) views, the context of their evolution and also key considerations for future private equity transactions in Australia.

Taxpayers awaited the Supreme Court of Canada’s (SCC) verdict in Copthorne with anxious anticipation in December, hoping for a roadmap to help ensure they don’t fall foul of the country’s GAAR. Joe Dalton investigates what the decision means for tax planning and how taxpayers can undertake an action with no business purpose, purely to achieve a tax benefit, without this being seen as an abuse of the Income Tax Act.

Over the next six months Republicans in each US state will vote for the candidate they want to represent the party in the upcoming November presidential election. With job creation likely to be one issue of central importance come then, the candidates’ tax policies could make or break their campaign. Matthew Gilleard investigates what the hopefuls have to say on corporate taxes.

The UK tax authorities have been trialling mediation as a new way of settling tax disputes. Ralph Cunningham finds out from a taxpayer and an adviser how it could reduce unnecessary time and money spent on litigation.