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For some time, the Chilean domestic law has been promoting the securitisation's activity due to the benefits that this form of financing could generate for the originators as well as for the investors. The mechanisms that encourage and make possible the development of this industry are given from a civil perspective (reduction of paperwork at the assignment; limitations to the defense of the transferred debtor), as well as from a tax perspective.

Janne Juusela Tax treaty with India The government has issued a bill (HE 286/2009) enforcing the tax treaty between Finland and India. The primary purpose of the treaty is to avoid international double taxation and to prevent tax avoidance. The treaty was signed in New Delhi in January 15 2010.

Besides the well known features of the long standing Belgian holding regime, Belgian holding companies can also benefit from some of the more recent, attractive attributes of the Belgian tax system, explain Paul Op de Beeck and Luc van Walleghem of KPMG

Despite other advantages, the corporate tax regime can make the US an unwelcome place in which to invest. Erin Kelechava finds out about what needs to change if America is to attract more holding companies

Satya Poddar and Shalini Mathur of Ernst & Young outline how India's new goods and services tax will eventually drastically overhaul the country's indirect tax system for the better, despite constant disputes between the centre and the states.

K R Girish and Sunil Lala of KPMG explain how changes to dispute resolution methods and the introduction of alternative techniques look to reduce litigation costs and clear the backlog of cases building up within the country.

Its tax treatment of capital gains, repatriation and dividends, for example, makes Cyprus stand out as a holding company location, believes Sophie Stylianou of Eurofast Taxand.

Stefan Ditsch and Barbara Zuber of PricewaterhouseCoopers explain that while Germany takes European Commission objections to its tax system seriously most of the time, on some issues, such as withholding tax on outbound dividends, Germany is not prepared to yield

Sophie Stylianou Simeon Grigorov Bulgaria's transfer pricing regulations are in line with the arm's-length principle, under Ordinance H-9 of August 14 2006 of the minister of finance on Procedure and Ways of Application of the Methods for Determining Market Prices (effective from September 2 2006), though they needed further clarification, as far as the requirements of the authorities were concerned. In line with this, and bearing in mind that the arm's length principle should be preserved, the transfer price used in transactions between related parties should be comparable to the price that would have been used had the parties involved been independent. For this purpose, a related-party relationship, for tax purposes, is established where a minimum shareholding of 5% exists between the parties.

By Katharina Padrutt, TAX EXPERT International, Zurich