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  • Drilona Likaj The Assistance for Tax General Directorate twinning project between the Albanian authorities, the Swedish Tax Agency and the French Public Finances General Directorate is aimed at supporting the Albanian Tax General Directorate in making sure the country's tax legislation and procedures are in line with other EU member states. The project is funded by the EU and has a value of €2.2 million ($3.2 million). The project started in March 2010 and will finish in March 2012.
  • Alexander Hofmann of Hofmann Law runs through Austria’s latest attempts to improve its banking secrecy and discovers that the country needs to make more concessions to global standards if it wants to shrug off its tax haven image.
  • A number of meetings have been held in recent months to discuss the future of transfer pricing in Africa. African governments, along with developed countries around the world, are proving their commitment to build up the transfer pricing systems in sub-Saharan Africa but a number of challenges stand in the way. Sophie Ashley builds a picture of transfer pricing today; how far has it come and how far does it need to go?
  • Suryohadi An Indonesian internet provider (Indo Co) entered into a contract with a UK-resident global satellite operator (Sat Co) for the use of bandwidth, and paid bandwidth leasing fees. Indo Co did not use all the available bandwidth and sold remaining bandwidth to customers who paid leasing fees proportional to the size of bandwidth used.
  • Hélène Rives Philippe Durand "It is not for the tax authorities to comment on the appropriateness of the way in which a company manages its cash", declared the Conseil d'Etat, in a case which is likely to have a great impact on the way in which French companies are able to manage their cash reserves.
  • In recent years there has been a great deal of interest in corporate migrations out of the UK. But a non-UK group becoming UK headquartered is an area that has received somewhat less attention. Simon Letherman, Ansgar Simon, Don Lonczak and Iain Scoon of Shearman & Sterling in London and New York explore why US groups are attracted by inverting into Europe, and particularly the UK.
  • Over the past decade or so, Canada has been struggling with the problem of how to effectively deploy their audit verification personnel in the face of increasing complexity in both the applicable domestic tax laws and the transactions and structures used by taxpayers. John Yuan and Chia-yi Chua of McCarthy Tétrault in Toronto explain how the Canada Revenue Agency have begun to employ some form of risk analysis to assist with their internal decision making on what type of taxpayers or issues to pursue.
  • India refused to consider a settlement in the Vodafone tax dispute despite a request from the Dutch government to begin negotiations.
  • International Tax Review broke new ground last month with the presentation of awards for the leading in-house tax teams in Europe for direct and indirect tax.
  • Sean Foley Landon McGrew The US Treasury Department recently released final regulations providing guidance on the reduction of the number of foreign tax credit limitation categories under section 904(d) of the Internal Revenue Code (TD 9521). The final regulations generally adopt the temporary regulations (issued in December 2007) which reduced the number of foreign tax credit limitation categories from eight to two, general and passive. The final regulations, like the temporary regulations, are generally effective for taxable years ending after December 31 2006.