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Taxpayers in Russia will have to wait much longer than they thought for new transfer pricing rules after the State Duma failed to adopt the law in time for their enactment, as expected, on January 1.

The European Court of Justice (ECJ) ruled in favour of the taxpayer in two cases that looked at whether leasing transactions were set up to avoid VAT. However, in one case, there are still some questions for the UK courts to decide concerning abusive practice.

Saudi Arabia has sought to reduce the risk of double taxation by introducing participation exemption rules for the first time, though the order fails to clarify important details about how the rules will work, such as when they will come into force.

Finn Eide Unusually, 2010 passed by without any dramatic changes in the Norwegian tax regime. But that does not mean there is nothing to report from Norway. There was transfer pricing and transfer pricing once more.

Dieter Endres The 2008 interest limitation replaced a thin capital rule disallowing interest on shareholder finance in excess of 1.5 times the shareholders' equity brought forward. The thin capital rule was based on the previous imputation system of corporation tax and consequently only applied to significant shareholders without their own general income or corporation tax liability. Thus, only tax exempt persons or foreigners were caught. Naturally, there are far fewer tax exempt (charities, trade unions, political parties, basketball clubs and the like) than foreign shareholders, which led the ECJ to see the rule as mainly aimed at foreign interests, vehement government protests notwithstanding. Accordingly, it was an unacceptable hindrance on an EU citizen's freedom of establishment (case C-324/00 Lankhorst-Hohorst judgment of December 12 2002).

Ron Richler Edward Miller In St. Michael Trust Corp. v The Queen (commonly referred to as Garron), the Federal Court of Appeal (FCA) dismissed the taxpayer's appeal from the Tax Court of Canada (TCC). The tax planning objective in this case was to use offshore trusts that would not be subject to Canadian tax. The FCA upheld the TCC's decision that the offshore trusts were taxable in Canada.

Another year of transfer pricing development brings hope, for taxpayers and their advisers, that processes will be streamlined, guidelines will provide clarity and policy reform will allow for better interpretation. A new year allows for contemplation about the direction governments and tax authorities should take. Sophie Ashley reports on the expectations of global and regional advances.

International Tax Review will present its sixth annual European Tax Awards at the Dorchester Hotel in London on May 18 2011.

Deloitte has a new head of its UK tax practice. Andrew Hodge has become the managing partner, succeeding David Sproul, who becomes chief executive and senior partner of Deloitte in the UK in June 2011. Hodge is the head of the firm's UK and EMEA global employer services businesses.

Reed Smith have appointed Caspar Fox as a tax lawyer in London. Fox joins from Eversheds, having held the position of head of corporate tax whilst there. He has wide-ranging experience in corporate and finance transactions, but his particular focus lies in M&A, private equity and financial services work.