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Gary James of BDO in Hong Kong outlines changes to the approach taken by China towards anti-avoidance and urges taxpayers to critically consider their structures and practices.

Fulvia Astolfi and Serena Pietrosanti of Hogan Lovells discuss recent developments in the Italian real estate rules and explain that while the changes will affect all aspects of the sector, many transitional provisions have been set up to minimise problems.

Álvaro de la Cueva On March 17 2011, the Spanish Supreme Court handed down an interesting judgment on the application of the thin capitalisation rule in situations of indirect indebtedness with a shareholder resident in a country with which Spain has signed a tax treaty for the avoidance of international double taxation. The indirect indebtedness issue has been highly debated in Spain.

Sean Foley Landon McGrew The Internal Revenue Service (IRS) recently announced the selection of Samuel Maruca as the transfer pricing director in the IRS' Large Business and International division (LB&I). The transfer pricing director position is a newly-created executive-level position that will lead the LB&I division's transfer pricing practice. The transfer pricing practice was created in the fall of 2010 as part of the realignment and renaming of the IRS Large and Midsize Business division as the LB&I division.

Peter Dachs The Draft Taxation Laws Amendment Bill, 2011 has been released. It contains far reaching amendments to South Africa's tax rules relating to cross-border transactions.

Sead Dado Salkovic Under the provisions of the Corporate Income Tax Law of Montenegro, capital gain is considered the income derived from the sale or other transfer of assets such as land, buildings, property rights, equity in the capital or securities against consideration.

Elena Kostovska April was a month of amendments for a number of FYR Macedonian tax laws. In addition to the changes introduced in the Profit Tax Law, the Property Tax Law was also amended. Certain provisions became effective immediately while others will enter into force from 2012 (appeal section).

Gerry Thornton Ciara Breslin The Irish government has recently published legislative proposals to enhance the flexibility of Ireland's attractive 25% R&D tax credit.

Jul Seventa Tarigan To avoid higher taxes on income, individuals that are subject to progressive tax rates usually split their taxable income by transferring their income to other people. Through this, it is possible to lower the effective tax rate since the lower income in the hands of the transferee will be subject to lower tax rate. In a cross-border investment, workers who are dispatched by the investor/parent company to its subsidiary may be subject to very high taxes on individual income in the country where the investment was made. To avoid this situation, the parent company would usually absorb the employee's income generated in the other country by classifying the worker's income as a management fee, technical fee, or other kind of fee that is being paid by the subsidiary to the parent company.

Zoe Kokoni The Cyprus-Slovenia income tax treaty and the Protocol to the treaty, which was signed on October 12 2010 was ratified by Slovenia on March 7 2011. The new treaty will replace the existing treaty of Cyprus-Former Yugoslavia that was signed back in 1985.