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  • The tax authorities are ready to develop the elements required for the evolution of transfer pricing practice, say Claudia González-Béndiksen and Paola Gutiérrez of Baker & McKenzie
  • In the last two years, several transfer pricing resolutions have been approved, say Diego González-Béndiksen and Rosa Maria Gil of Baker & McKenzie
  • Rüdiger Loitz, Tobias Taetzner and Tom Weber explain how finance can help improve tax effectiveness
  • Julie Zhang has joined Mayer Brown JSM to lead the firm's tax practice in China, which will offer tax transaction and controversy services. Two other tax lawyers are joining the Beijing office at the same time. Zhang specialises in tax planning and tax implications of PRC and international corporate transactions.
  • Paul Chambers Samantha Nonnenkamp On June 2 2008, Luxembourg and India finally signed a double tax treaty (DTT) that will probably take effect on January 1 2009. While the treaty is based on the OECD model tax convention, the version actually used is much older than the one applied now. Indeed the version used likely dates back to before 2000. This is most probably a reflection on the extraordinary amount of time it took to come to an agreement.
  • The Australian government's recently released green paper on the carbon pollution reduction scheme (CPRS) sets out its proposal for a 'cap and trade' emissions trading scheme to be introduced in Australia from 2010. Under the CPRS, the government will place a limit, or cap, on the amount of carbon pollution 'industry' can emit. The CPRS will require affected businesses and industries to buy a 'pollution permit' for each tonne of carbon they emit, creating an incentive to reduce pollution. The intention is for the permits to be auctioned by government with a transitional period cap on the price paid. The permits would be tradeable so that permits can be bought by industries that value them most highly. Non tax deductible penalties will apply where emissions exceed permitted levels.
  • Marc Tahon On June 27 2008 the council of ministers approved a draft bill of law that intends to align Belgian tax legislation with the European fiscal merger directive (directive 90/434/EC of the council d.d. July 231999, as amended by directive 2005/19/EC of the council d.d. February 172005 – hereafter the merger directive). The draft bill was submitted to parliament on July 24 2008 for approval. This is a second attempt after a first initiative of the former government in 2007 failed to make it to law. The new rules are meant to enter into force as of the date of publication of the bill. This is expected to occur somewhere in the last quarter of 2008. Meanwhile the law of June 8 2008 implementing the company law merger directive (directive 2005/56/EC of the European Parliament and the council d.d. October 26 2005) has come into effect so that henceforth a clear set of company law rules exists for effecting a cross-border merger involving a Belgian limited liability company.
  • Stefan Ditsch Ulrike Meier-Holzgräbe Businesses in Germany generally pay two income taxes, trade and corporation tax. The total burden is usually some 30%. Half of this is the standard 15% corporation tax, but the other half comes from the trade tax levied at local rates. These range from 7% in Norderfriedrichskoog to 17.15% in Munich.
  • Georgiana Head talks to Ian Andersen about developing tax rules for the Qatar Financial Authority
  • The tax authorities in Brazil have extended the meaning of tax haven as it applies to transfer pricing. Now they should issue an updated list of privileged tax regimes that the new rules apply to, believes Luiz Felipe Ferraz of Demarest e Almeida