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  • Although the UK's transfer pricing requirements are onerous, HMRC is attempting to make things easier for companies. Shiv Mahalingham of Alvarez & Marsal Taxand UK explains why hope is in sight
  • Chandrima Bhattacharya, Manish Matta and R Vivek Dharma Sankaran of Deloitte Haskins & Sells say the Indian government should forge more careful tax policies if it wants to maintain India's advantages
  • Ulrich Ammelung and Christian Altvater of PricewaterhouseCoopers explain how the fallout from the credit crisis has had a major impact on the tax position of German banks
  • The full effects of a new flat rate business tax on taxpayers have yet to be seen, believe Karol Campo, Santiago Chacon and Terri Grosselin of Ernst & Young
  • Michael Desmond is rejoining McKee Nelson in Washington DC as chairman of the firm's tax practice. He left the firm three years ago to become tax legislative counsel in the US Treasury Department.
  • Sean Foley The IRS has issued final and temporary regulations (T.D. 9400) under section 367(b) providing guidance on certain triangular reorganizations (commonly referred to as "Killer B" transactions) involving one or more foreign corporations. The IRS and Treasury believe that these transactions raise policy concerns because they can allow the effective repatriation of a subsidiary's earnings without the imposition of US tax. The regulations generally apply to transactions occurring on or after May 23 2008 (however, see the discussion below).
  • Poland is on the march. The biggest of the countries that joined the EU in 2004 has quickly asserted itself at the Commission in Brussels. European officials take the views of its leaders seriously. The country is also trying to make a name for itself as an investment location. It is doing its utmost to get all the different elements required for this into place. One of the key features that attracts investors to a country is a modern tax system. One that has low rates and reduced complexity. However, not only is Poland is trying hard to bring international companies in, so are its neighbours, even if they are fellow members of the EU. Tax competition is fierce in Europe.
  • Paul Stepak Tracey Woo On April 22 2008, the Tax Court of Canada released its decision in Prevost Car Inc. v. The Queen (Prevost). At issue was whether a Netherlands holding company (BV) was the beneficial owner of dividends paid by its Canadian subsidiary, Prevost Car, for purposes of the reduced withholding tax rate on dividends under the Canada-Netherlands income tax convention (treaty).
  • Neil Wilson In the last few years, the increase in globalisation and the application of new technologies has led to major changes in the way business is done. Over the same period there has been a transformation in the approach by the regulators, with many countries around the world implementing more rigorous corporate governance regimes. This changing business environment has had a dramatic impact on the management of taxation by businesses.