Search results for

In the last in a series of 10 articles on tax-effective intellectual property management, Pim Fris, Sebastien Gonnet and Emmanuel Llinares of NERA provide an analytical framework to address location-specific advantages from a transfer pricing perspective.

The implementing regulations to the EC VAT Directive have resulted in an interpretation issue with VAT fixed establishments. Björn Ahrens and Michael Häring of PwC explain why the German tax authorities’ interpretation of the term is at least misleading and what the practical consequences of such interpretations might be.

After almost a decade of intense developments and numerous new regulations, ordinances and administrative principles on transfer pricing in Germany (including the widely commented on introduction of the rules on transfers of business functions), 2011 has been a quiet year. This should not, however, lead to the conclusion that the German Ministry of Finance has shifted its focus away from transfer pricing matters or is taking time to reflect on the comprehensive rules introduced so far before deciding what steps to take next. Lorenz Bernhardt and Michael Jakob of PwC run-through the anticipated tax developments in German transfer pricing.

Despite the European debt crisis, Germany’s fiscal revenue in 2011 will be much higher than estimated. However, it remains uncertain whether the discussion about an abolition of the solidarity surcharge and reduction of income tax rates will survive the Christmas holidays. But it proves true that German tax law always has interesting news to report even if there no major tax reforms. Stefan Ditsch, Barbara Zuber and Alexander Just of PwC discuss Germany’s tax developments.

On July 15 the Internal Revenue Service’s (IRS) Large Business & International (LB&I) division issued guidance to IRS examiners and examination case managers in the form of a directive concerning the application of the economic substance doctrine (ESD) that was recently codified in section 7701(o) of the Internal Revenue Code. Andrew Kim and William Skinner of Fenwick & West explain how taxpayers can navigate through the ESD, and also discuss recent US tax developments.

Former US Treasury official Joshua Odintz has joined Baker & McKenzie’s tax practice as a partner in Washington, DC where he will deal with tax controversy and tax policy issues.

The government has appointed two new salaried judges of the First-tier Tax Tribunal.

Julia Gillard’s Australian government continues to face strong criticism from business with regards to the controversial minerals resource rent tax (MRRT).

A carbon tax on coal, crude oil and petroleum products could be introduced by the Japanese government as early as April 2012, according to environment minister Goshi Hosono.

The UK government’s senior tax professional will step down next summer.