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Vladimir Kotenko On August 26 2009 the cabinet of ministers passed resolution no. 895 attempting to restrict tax deductibility of foreign currency exchange losses. Specifically, taxpayers were strongly discouraged from deducting unrealised currency exchange losses resulting from revaluation of loans and some other foreign currency liabilities. The resolution blatantly contradicted the CPT Law.

Janne Juusela The Finnish tax system has been amended regarding the payment of most indirect taxes. These include VAT, income tax deducted at source, employers' social security contribution, withholding tax, insurance premium tax, and lottery tax.

David Shapiro David Shapiro has rejoined PricewaterhouseCoopers in Washington, after leaving his position as senior counsel at the US Treasury.

Ian Farmer With less than six months to go until the Henry Review must submit its recommendations to the government, the tax reform process is at a very interesting point.

Caitriona McGonagle has joined William Fry Tax Advisors - Taxand in Ireland as a consultant. She was formerly a partner at Matheson Ormsby Prentice, which she left in April.

Javier Montes Urdín Great strides have been made in Spanish transfer pricing legislation and audit practice in the past three years. Indeed, until December 2006, Spain was viewed by transfer pricing practitioners as a transfer pricing heaven where the scarce legislation existing at that time lay the burden of proof with the tax authorities, who were unable to audit the transfer pricing policy of Spanish or foreign multinationals operating in Spain in a proper manner, due to the lack of specific documentation and training.

Sean Foley Landon McGrew The IRS and Treasury department recently released final regulations (TD 9452) addressing the application of separate foreign tax credit limitations to dividends received from 10/50 corporations.

Henry An David Jin-Young Lee The National Tax Service (NTS) released tax audit guidelines for 2009 in September. These guidelines provide details on the criteria used to select companies for regular tax audit for 2009. The guidelines were developed in consultation with the Audit Selection Review Committee and the Advisory Committee for National Tax Administration. The announcement is intended to enhance transparency and predictability for taxpayers.

Sophie Stylianou For companies active in the development and licensing of intellectual property (IP) rights, efficient ownership structuring is vital. The direction of the relevant licence payment is also important so as to make transactions as tax efficient as possible.

By David Stevenson