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Rajendra Nayak Ganesh Pai The Authority for Advance Rulings in India (AAR) in the case of Foster's Australia Ltd. vs CIT (unreported) recently examined the taxability of income earned from the transfer of intangible property. The taxpayer was a non-resident company incorporated in Australia and was engaged in the business of brewing, processing, packaging, marketing, promoting and selling of beer products in Australia and abroad. It had a brand license agreement (BLA) with its Indian subsidiary by virtue of which, the Indian subsidiary could brew, process, distribute etc beer products in India and it also had exclusive right to use the associated trademarks within India.

Tobias Taetzner Florian Hölzerkopf The tax playing field for German companies in 2008 is entirely new. Two of the more radical changes are:

Fewer capital markets transactions may be taking place now in some parts of the world, but that does not mean tax has lessened in importance. While some countries struggle to revive deal making, others are racing to develop their financial systems. The tax positions of financial institutions have certainly changed in the last 12 months and any deals that are being done come under the scrutiny of tax authorities. It adds up to capital markets investors needing to rely more than ever on high-quality advice and knowledge from their tax practitioners.

By Joanna Faith

Ireland has become a jurisdiction of choice for making equity investments in China and Japan, say David Lawless and Sean Murray of Dillon Eustace

Oliver Wehnert of Ernst & Young assesses Germany's new transfer pricing regulations

Transfer pricing comes out as the key issue for tax executives in nearly all surveys that International Tax Review conducts.

David Forst and James Fuller of Fenwick & West analyse recent international tax developments, covering foreign tax credits, foreign tax structured transactions, passive foreign investment companies and exchange-traded notes, that are potentially of interest to financial service industry participants in capital markets

Alexei Kuznetsov and Irina Bykhovskaya of Ernst & Young comment on why a financial institution may need to employ transfer pricing methodologies in its Russian operations

As investors continue to pour money into the local Brazilian capital markets, it is crucial for them to understand how they will be taxed, believe Simone Frizzo and Carlos Romero of Ernst & Young