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Deloitte has announced that former tax partner Barry Salzberg has been chosen to take over the position of global chief executive officer. Salzberg will replace Jim Quigley, who has completed his term, from June 1 2011.

Steve Snyder has joined the Atlanta office of PwC in the transfer pricing controversy practice.

Vladimir Kotenko The first quarter of 2011 has been a challenge. Moreover, we're probably seeing only the tip of the iceberg, since the problems with implementing the new tax code are constantly evolving. The tax authorities' views are often inconsistent and offer little comfort to taxpayers because of their non-binding nature.

The nominations for the inaugural Euromoney Legal Media Group European Women in Business Law Awards have been announced. For the nominees in the individual practice areas and firm awards, please see below. Categories include Tax and Transfer Pricing.

Rafael Calvo On January 12 2011, the European Commission handed down its decision declaring that article 12(5) of the Spanish Corporate Income Tax Law (according to which a Spanish company may amortise for tax purposes over 20 years the financial goodwill resulting from the acquisition of certain qualifying foreign shareholdings) amounted to illegal State aid as regards acquisitions in non-EU countries (no 45/2007, EC's press release reference no IP/11/26). On October 2009 the European Commission already declared that the deduction of the financial goodwill arising in the acquisition of EU subsidiaries was an illegal state aid subject to (limited) recovery.

Javier Montes Spanish profit participation loans (PPL) are hybrid instruments used in business finance, which combine the features of both equity (capital) and borrowing (loans). Their basic civil law form is that of a loan where all or part of the remuneration given to the lender for lending his money is made by reference to the business performance of the borrower. According to the legislation in force, PPL qualify as liabilities, but, as provided by Royal Decree 7/1996, are considered net equity for the purposes of capital reduction and company dissolution situation as established in mercantile legislation.

Sean Foley Landon McGrew The Internal Revenue Service (IRS) recently issued its annual Announcement and Report Concerning Advance Pricing Agreements (APA report). The calendar year 2011 marks the 20th year of the IRS' APA programme. Since 1991, the IRS's APA programme has provided taxpayers with an opportunity to enter into an agreement with the IRS on a transfer pricing method prior to filing a tax return. This year's report describes the experience, structure, and activities of the IRS's APA programme during calendar year 2010.

Slobodan Mihajlovic At the beginning of the 21st century, with the tax reforms in place, Serbia was the leader in the incentives granted to the expatriates. However, as the years progressed, expatriate's benefits were slowly but steadily diminished and now expatriates and Serbian residents are equalised. Therefore, for those who earns more than RSD1,708,200 ($24,000) in and from Serbia, it is obligatory to submit an annual income tax return.

Paulo Núncio Tiago Cassiano Neves Portugal's double taxation treaty (DTT) network includes 54 tax treaties in force. Most of the treaties concluded by Portugal follow the OECD model, with a number of treaties (especially the older treaties) containing provisions which are based on the UN model.

Nathalie Urban Ruth Kälin The Schaffhausen government has submitted a draft revision of the cantonal tax law to the cantonal parliament. Among others, the draft foresees a reduction of the statutory corporate income tax rate from 5% to 4% from January 1 2013.