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  • Google is under audit in the US following reports it uses transfer pricing to reduce its overseas effective tax rate down to just 2.4%.
  • Maja Arcyz has joined KPMG in the US, taking on the role of managing director in the firm’s International Corporate Services practice in New York.
  • Milind Kothari and Gaurav Shah of MZS & Associates analyse, with the aid of Indian case law, the challenges taxpayers in the shipping industry face from a cross-border tax and transfer pricing perspective.
  • In two separate judgments Delhi High Court ruled on the tax liability of Rolls Royce and Rolls Royce Singapore due to their operations in India. Common issue in both the matters was exposure to a permanent establishment (PE) in India and quantum of profits to be attributed to operations carried out by the PE in India. Sunil Jain of J Sagar & Associates investigates.
  • One of the least discussed proposed provisions in India’s Direct Taxes Code is the branch profits tax. The new law proposes to tax profits of the branches of the foreign companies carrying on business in India. Ajit Korde, Commissioner of Income Tax, Indian Revenue Service, discusses some of the aspects of the tax and argues that it should be higher up on taxpayer’s agendas.
  • One issue in the case relates to the use of comparable data not available to the taxpayer The case of Symantec Software Solutions Pvt Ltd, heard before the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT), has implications for the application of transfer pricing provisions, which continue to differ from global best practice.
  • Lawyers from Baker & McKenzie investigate transfer pricing law and developments from across the region.
  • With elections on the way for 2012 in a number of countries in the Central American region, Rafael Sayagués of Ernst & Young considers the most important aspects of tax policy that will be focused on in the coming years
  • Marienne Mendonça Shiota Coutinho looks at Brazil’s evolution in the international tax arena and what this means for foreign investors
  • The trend in rising VAT rates around the world shows no sign of abating as governments, desperate to balance their budgets amid falling corporate tax revenues look to make a fast buck.