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  • Sometime after key litigation, important questions to do with the net basis of withholding taxes in Europe have still not been resolved, explain Barry Larking and Robert van der Jagt of KPMG Meijburg & Co
  • By Erin Kelechava
  • by Jack Grocott
  • A key lesson of the global volume recession in 2008 and 2009 is that transfer pricing benchmarking and comparability studies need to be revised to take account of changing economic conditions, explain Seen Meng Chew and Harlow Higinbotham of NERA Economic Consulting
  • French groups have more flexibility to decide how to divide the tax burden among its members after two Supreme Court decisions. However, the rulings could also change how M&A take place when it involves entities that have suffered losses, explain Renaud Jouffroy and Jean Sayag of Landwell et Associés
  • by Esther Martin
  • Andrés Edelstein Ignacio Rodríguez Argentina was actively reviewing two key areas of its tax system at the end of March. One area consists of the draft bill that the Executive Branch sent to the Congress introducing changes to the Tax Criminal Law. The other, although not as broad as some may have wished, relates to a distortive tax that affects the Argentine economy. Tax Criminal Law amendments
  • Bryan Bailey Andrew Spiro In delivering its budget on March 4 2010, the Canadian federal government announced a significant liberalisation of Canadian tax laws applicable to non-resident investors in Canadian businesses.
  • Sean Foley Landon McGrew The US Court of Appeals for the Ninth Circuit has re-issued its opinion in Xilinx, Inc. v. CIR, No. 06-74246 (9th Circuit March 22 2010), holding that stock-based compensation costs incurred in connection with a cost sharing arrangement were not required to be shared. This decision reverses an earlier Ninth Circuit opinion (Xilinx, Inc. v. CIR, No. 06-74246 (9th Circuit May 27, 2009) which held that such costs were required to be shared, even if such costs would not have been shared in an arm's length transaction. The court withdrew its earlier opinion before the issuance of the new opinion. The court's re-issued opinion also affirms the Tax Court's decision in Xilinx, Inc v CIR, 125 T.C. 37 (2005).
  • Two advisers have become partners of Freshfields Bruckhaus Deringer.