Search results for

Caroline Silberztein, head of the transfer pricing unit in the OECD centre for tax policy and administration answers Catherine Snowdon's questions about the problems that face APA programmes today and how the OECD will work to improve its guidelines in this area.

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.

Eiki Kawakami of Kojima Law Offices-Taxand looks back at a busy few months for the Japanese tax system. Politics and disputes have been keeping taxpayers busier than ever with a number of important decisions making many think twice about how they structure their work.

Kathleen Penny Josh Jones Non-residents of Canada that dispose of taxable Canadian property (TCP) are taxable in Canada, subject to treaty relief. Before March 5 2010, all private Canadian corporations' shares were TCP. As of March 5 2010, Canadian shares are generally not TCP unless, at any time in the 60-month period preceding disposition, they derived more than 50% of their value directly or indirectly from Canadian real or resource property. On July 12 2010, the legislation implementing this change became law.

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:

Andrés Edelstein Ignacio Rodríguez The Supreme Court of Justice issued an unpredictable opinion in mid-June in the Hermitage case questioning the constitutionality of the Argentine Minimum Notional Income Tax (MNIT).

Megan Lapwood and Mark Atkinson of Deloitte in Switzerland describe how cross guarantees and the overall flow of benefits derived within a multinational group from external funding may affect how guarantee fees should be charged.

Sergiy Melnyk of Salans in Ukraine describes how the new draft tax code in Ukraine constitutes a significant departure from previous international tax provisions in the country.

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.

Tax executives are being placed under extra pressure. Their busy times are no longer just at year end, they are all year round. This is where external advisers step in to reduce the workload. Jack Grocott analyses the results of the Asia-Pacific Client Services Poll 2010 and investigates the problems executives are facing and how advisers can help.