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German banks should put their strategy into place now if they want to be ready for the flat tax. Hans-Ulrich Lauermann and Benjamin Laves of PricewaterhouseCoopers explain why

In 2007 Germany reformed its tax system to make itself more attractive to foreign investors. Stefan Ditsch, of PricewaterhouseCoopers, explains

Rebel Curd, Robin Hart, and Catie Magelssen of the Ballentine Barbera Group, a CRA International company, explore the potential for risk in an investment model recently published by the IRS

Jorge Mesta and Hernan Katz praise the economic revival in the region in recent years, but warn that countries must prepare themselves properly for the risks and challenges ahead

If applied based on sound economic principles, contribution analyses are powerful tools to address the bulk of most complex transfer pricing issues, explain Sébastien Gonnet & Pim Fris of NERA Economic Consulting

Multinational companies have identified Latin America as one of the up-and-coming areas of the global economy. More and more investment is coming into the region in all sectors, for example, financial services and energy. There are regional economic agreements such as Mercosur and the Andean Pact, but tax rules are not uniform in the region and taxpayers have to deal with different laws in each country.

Rajendra Nayak Ganesh Pai The Mumbai bench of the income tax appellate tribunal (ITAT) in the case of Bharat Petroleum Corporation Ltd vs JCIT (2007) 111 TTJ (Jd) 375 examined the taxability of fees paid to a non-resident for conducting a market study. The taxpayer is a company incorporated in India and is engaged in the business of refining crude oil and marketing petroleum products. The taxpayer appointed a consultant for conducting a market study which covered among other things; supply and demand analysis and price forecast. The market study was an update of an earlier market study undertaken by the consultant for the taxpayer. The issue before the ITAT was the taxability of the fees paid by the taxpayer to the consultant for the update of the market study. India has entered into a double taxation avoidance agreement with Singapore (treaty). The consultant was a resident of Singapore within the meaning of article 4 of the treaty and was therefore eligible for the benefits.

Gagnon Jean On November 13, 2007, the Department of Finance tabled a Notice of Ways and means motion to implement proposed amendments to the Income Tax Act partly in response to fiscal policies previously anno-unced. The amendments include the following measures:

A third round of public consultation on new international tax rules was announced by the New Zealand government at the beginning of December.

By Catherine Snowdon, Americas correspondent