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Nélio Weiss Philippe Jeffrey As widely known, Brazil's transfer pricing rules do not adopt the internationally accepted arm's-length standard. For instance, for the purposes of applying the Brazilian equivalent to the resale price method (PRL) in transactions involving import of goods between related parties abroad, regulations provide the use of statutory fixed margins to derive a benchmark ceiling price. In these instances, actual transfer pricing practiced by the local tested party must be lower than that derived benchmark price, otherwise tax authorities will impose a transfer pricing adjustment.

Royal Decree-Law 9/2011 has temporary modified the VAT rate applicable to first supplies of dwellings in Spain, which has been reduced from 8% to 4% until December 31 2011. The Royal Decree-Law justifies the measure for political reasons because of the specific economic situations and the considerable effects it is intended to produce. Eduardo Gracia and Ricardo García-Borregón of Ashurst look at who really benefits.

Brazil’s economy, which expanded by 7.5% last year, remains an attractive prospect for foreign investors. Yet for those doing business in the country, the picture is not entirely rosy. Paying tax is becoming a much more difficult and precarious business. As the revenue authorities adopt a more aggressive stance, companies are increasingly facing the risk of controversy and litigation. Reuben Bard-Rosenberg investigates.

Connecticut is chasing $269 million from Amazon

Transfer pricing activity has increased significantly in the past year in Vietnam with the government vowing to take the issue more seriously and investigate companies that are repeatedly reporting losses in the country. With a recent announcement of a pilot APA programme, Thomas McClelland, the chairman of EuroCham’s (European chamber of commerce in Vietnam) Tax and Transfer Pricing Committee, discusses what this means for businesses operating in the country.

One of the few transfer pricing cases to go to trial in the US in the last decade won an Americas Tax Award from International Tax Review for Symantec, the taxpayer at the centre of the litigation.

On September 15 2011, the Dutch government published its 2012 budget proposals. The proposals include further limitations on the tax deduction of interest payments by acquisition holding companies and the introduction of a revised exemption for foreign branch profits. In addition, anti-abuse provisions are proposed in connection with the taxation of non-Dutch resident corporate shareholders in Dutch companies and the levy of dividend withholding tax on certain profit distributions made by Dutch co-operatives. René van Eldonk and Steven den Boer of Simmons & Simmons analyse the proposals.

The income tax treaty that was signed back in October 2009 for the avoidance of double taxation and prevention of fiscal evasion between Albania and Ireland entered into force on July 12 2011 and will be applicable from January 1 2012.

World Tax 2012, International Tax Review's directory of the leading tax advisory firms around the world is now available online.

In recent years, the courts of both lower and higher courts have ruled in favour of the tax authorities. It is interesting to learn from the lessons of this development.