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  • Property funds remain entitled to significant tax savings under new rules. But Chinapat Visuttipat of HNP COUNSEL Taxand in Thailand warns that careful planning must be carried out before venturing into this type of investment.
  • Since the arm's-length principle was introduced in Peru in 2001, there have been multiple updates and extensions to the rules on transfer pricing. Claudia González-Béndiksen and Paola Gutiérrez list the important points taxpayers must be aware of, such as maintaining stringent documentation as well as filing an annual sworn informative return.
  • Transfer pricing legislation is relatively new in Colombia and with taxpayers, advisers and officials still finding their way, questions are still being asked. Diego González-Béndiksen and Rhina Toro Infante warn severe penalities wait for those who do not manage to comply.
  • In Chile, the rules technically follow the OECD guidelines, but Miguel Zamora and Ana Paula Güitrón say it is not clear whether this is true. Advisers still struggle to know which transfer pricing methods are allowed.
  • The Caribbean island state of Antigua and Barbuda has engaged US law firm Rubenstein & Rubenstein to rewrite a selection of the jurisdiction's tax laws.
  • Dieter Endres Those involved with tax groups in Germany often see the mechanism as clumsy, archaic and legally insecure. Accordingly, the governing coalition has undertaken to look at possible reforms in some detail. Anxious to push things forward, the provincial government of Hesse has summarised its ideas in a position paper for public debate. Its basic suggestion is to move from the present, rigid system of concentrating all profits and losses on the parent to a flexible system allowing group members to transfer their results with tax effect within the group. The main features of the proposal are:
  • Nicole Goulard Augustin Asselin The French Administrative Supreme Court decided on March 17 2010 that the stock option spread, equal to the difference between the market value of the underlying shares upon exercise and the exercise price of the options, is taxable in France "if the activity, that the grant of a stock option compensates, had been performed in France".
  • Taxpayers responded to the IRS' announcement about the reporting of uncertain tax positions with consternation. Erin Kelechava finds out that most corporate taxpayers regard Schedule UTP as a major departure from the relationship that has developed over decades between taxpayers and the IRS.
  • Several countries have announced or implemented VAT rises in the last few months. Salman Shaheen looks at the growing trend towards higher VAT around the world and why the global recession means it looks set to continue.
  • Silvania Tognetti has become a partner of Brasil Pereira Neto, Galdino, Macedo Advogados in Sao Paulo. She was formerly a partner of BM&A Consultoria Tributária – Taxand.