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KPMG has recruited two new tax partners from the firm's big-four competitors. Kenneth Harvey has joined the firm's international corporate services practice as a partner and will be based in Hong Kong for a three-year assignment. Harvey has extensive experience with tax matters relating to M&A, IRS tax controversy, as well as tax compliance engagements and regulation.

Petter Grüner John Spissøy The blooming oil and gas activities on the Norwegian continental shelf have now started to cool off. The activities have comprised everything from seismic activities to petroleum production, via test drilling, heavy lifting, wellhead services, construction projects etc. The tax consequences of an exit from the Norwegian continental shelf is essential for companies that have a taxable presence there.

Only a new VAT system in the EU will defeat missing trader intra-community fraud, believe John Benstead and Hassan Khan of the Khan Partnership

Peter Dachs The definition of a dividend is contained in section 1 of the Income Tax Act (Act). However, in terms of the revenue laws amendment bill it is proposed that this definition be replaced with a far simpler concept. However, this change will only occur from the date of replacement of secondary tax on companies (STC) with the new dividends tax. It is anticipated that this will occur in the last quarter of 2009.

Bob van der Made At the end of January 2008, the Dutch tax authorities announced their decision to reimburse Dutch dividend withholding tax to foreign EU based pension funds. The Dutch tax authorities said they would look closely, on a case by case basis, whether the claims were filed in a timely and correct manner and whether the foreign pension funds concerned can be considered to be equivalent to a pension fund in the Netherlands.

Rolf Declerck Like many industrialised countries, Japan has felt the bite of the credit crunch. That is why the Japanese government announced on December 12 2008 plans to encourage repatriation of overseas earnings in order to boost the Japanese economy. The fiscal package includes the introduction of the foreign dividend exclusion (FDE) system, supposed to enter into force by April 1 2009. Under Japanese tax law, dividends received from foreign subsidiaries, are taxed in the hands of the Japanese parent company. Double taxation is mitigated by an indirect foreign tax credit (FTC) for foreign corporate tax imposed on taxable income of the subsidiaries and a direct FTC for foreign withholding tax imposed on dividends. Meaning that for subsidiaries located in countries, including Belgium, with lower effective taxation compared to the Japanese corporate tax charge, the higher Japanese tax burden applies to the incoming dividends. The new rules go that dividends received from qualifying foreign subsidiaries will be exempt from Japan tax up to 95%. While the new tax rules imply that the indirect FTC for foreign withholding tax on the dividend distributions will be abolished, Belgian subsidiaries of Japanese multinationals should not be aversely affected due to Belgium's domestic withholding tax exemption, under certain conditions, for dividends that Belgian subsidiaries pay to their Japanese parent since Belgium has concluded a tax treaty with Japan.

Fernando Castro Silva André Pappamikail Branco The Portuguese parliament recently approved a budget supplement law that establishes the investment tax regime for qualified investments made in 2009 (RFAI 2009). Among other tax incentives, RFAI includes a new tax credit (up to 25% of the tax due) equal to 20% (for investments below €5,000,000 ($6,500,000) or 10% (for investments above €5,000,000) of the investments made during this year, which may be carried forward for four years. In addition, RFAI also includes an exemption on real estate transfer tax (IMT), property tax (IMI), and stamp tax on the acquisition of real estate for the purposes of the qualified investments.

US President Obama's budget request for the next financial year is projected to cost business $353.5 billion in higher taxes between 2010 and 2019.

The Hong Kong government has vowed to extend the country's tax treaty network to enhance its position as an international business and financial centre.

The New Zealand government is expecting increased pressure from the international community to reduce its corporate tax rate