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By Joanna Faith and Jack Grocott

Ian Crosbie and Raj Juneja of Davies Ward Phillips & Vineberg reveal how income trusts rose in popularity and analyse the legal changes that will likely end the use of these structures

Though it was late to introduce rules, Colombia is hurrying to update its transfer pricing system, report Diego González-Béndiksen and Rhina Toro Infante

Suzanne Boers In June the Dutch ministry of finance published a consultation document with a number of possible amendments to the Dutch Corporate Income Tax Act. With this, the Dutch government invited the public to submit comments and observations. The government is planning to submit a tax bill to the parliament this autumn, in which the final legislative proposals will be included. According to the consultation document, the amendments should enter into force as of January 1 2010.

David Cuellar Salvador Esquivel In the first half of 2009, the Mexican tax authorities issued annexes 16 and 16-A of the Tax Miscell-aneous Rules, which contain the instructions for the integration, characteristics and the guideline forms to file the statutory tax audit report and the questionnaires related to the public accountant's review, for the 2008 tax year.

Shane Hogan Gerry Thornton On July 28 2009, Ireland signed a tax information exchange agreement with Bermuda. This agreement will allow the Irish tax authorities to request information which is relevant to an Irish tax investigation directly from the Bermudan tax authorities (and vice versa).

David Cuellar Adriana Rodriguez Karina Perez Three advisers became partners of PricewaterhouseCoopers's tax practice in Mexico on July 1. David Cuellar and Adriana Rodriguez practise in the international tax services (consulting and structuring) team and Karina Perez is a dispute resolution specialist.

Sean Foley Landon McGrew The US Court of Appeals for the Ninth Circuit recently issued an opinion, in Xilinx, Inc v CIR, No. 06-74246 (9th Circuit May 27 2009), holding that the arm's length standard described in the section 482 regulations does not apply to certain costs incurred in connection with cost sharing arrangements. Rather, the court held that the section 482 regulations in effect at the time the taxpayer's tax returns were filed required the sharing of all costs incurred in connection with cost sharing arrangements, even if such costs would not have been shared by unrelated parties acting at arm's length. The Xilinx decision reverses an earlier Tax Court case (Xilinx, Inc v CIR, 125 T.C. 37 (2005)) that held that such costs were not required to be shared under section 482. On August 12 2009, Xilinx filed a petition for rehearing to the ninth circuit, arguing that the court had improperly abandoned the arm's length standard.

Henry An David Jin-Young Lee Various tax changes proposed by the Ministry of Strategy and Finance to help facilitate economic recovery have been approved for enactment.

Krzysztof Flis On July 13 2009 the Polish Supreme Administrative Court stated excise tax should still be deemed overpaid even if the underlying amount has been paid to the taxpayer by the customer in the price of goods (in other words the court stated that the tax provisions should be treated separately from the civil law concept of unjust enrichment).