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  • pyramids-of-giza50.jpg
    Egypt releases transfer pricing guidelines
    The Egyptian Tax Authority (ETA) has launched transfer pricing guidelines, after the introduction of legislation in 2005.
    December 13 2010
  • New decision on transfer pricing “may become important precedent” in Brazil
    Cristiane M. S. Magalhães and Iara M. S. Sousa do Amaral of Machado Associados explains why a decision of the Federal Regional Court of Appeals of the 3rd region (TRF) may become an important precedent for transfer pricing in Brazil.
    December 13 2010
  • treasury-50.png
    UK’s Finance Bill 2011 clarifies use of new OECD guidelines
    Draft clauses for Finance Bill 2011 in the UK refer to the updated OECD guidelines of July 2010 and make clear that, for accounting periods beginning on or after April 1 2011, this version is the one for business to refer to.
    December 10 2010
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    Recent US federal income tax developments
    As the US economy continues to sputter, it is perhaps not surprising that Congress and the administration have looked to change the country’s international tax rules to increase revenue. David Forst and Adam Halpern, partners at Fenwick & West, explain some of these changes, including legislative developments and new case law that will have implications for multinational corporations.
    December 09 2010
  • Concerns still surround Schedule UTP
    Schedule UTP has been been the subject of intense debate within corporate tax circles since the IRS announced the programme in January 2010. However, this programme is just the latest in a long line of IRS initiatives aimed at enhancing taxpayer transparency. Eli Dicker, chief tax counsel of the Tax Executives’ Institute, questions whether or not Schedule UTP will fundamentally alter the landscape.
    December 09 2010
  • US contemplates national sales tax
    As President Obama and tax policy specialists discuss ways to rein in a ballooning US debt, a national sales tax and changes to the corporate tax rate are beginning to look promising. By Elizabeth Bearese
    December 09 2010
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    Tax courts keep industry on their toes
    Officials have not proposed any significant changes to Germany’s tax law this year, but there have been some key court decisions and discussion about future reforms, that taxpayers need to be aware of, explains Stefan Ditsch of PwC
    December 09 2010
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    Anti-hybrid rules in the Canada-US tax treaty
    The anti-hybrid rules in the Canada-US income tax treaty are an example of good intentions gone astray. Jeffrey Trossman, tax partner at the Canadian law firm of Blake Cassels & Graydon discusses important changes contained in the treaty’s Fifth Protocol, and explains how they affect inbound investments into Canada.
    December 09 2010
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    Advocate General gives split opinion on effective place of management
    An adviser to the European Court of Justice recommended today that the court should approve an exemption for a taxpayer in France whose effective place of management was in a third country, outside the EU, but only under certain circumstances.
    December 09 2010
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    Lack of consensus for Bowles/Simpson plan is no surprise
    The failure of the National Commission on Fiscal Responsibility and Reform to secure a supermajority vote on its debt reduction plan on December 3 illustrates the difficulty of the work ahead for those who want to tackle tax reform.
    December 09 2010
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