Search results for

Akio Takisaki Along with the recent sharp increase of assessments due to transfer pricing, requests from industry and other taxpayers for improvements of the transfer pricing regulations have been increased. In response to such requests, the Liberal Democrats released a tax reform proposal in December 2006 which included the following three measures:

Rajendra Nayak Ganesh Pai The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) in the case of Sheraton International inc. vs. DDIT [2007] 293 ITR (AT) 68 examined the taxability of a foreign company engaged in the business of providing various services related to hotels. The taxpayer (US Co), a company incorporated in the US, entered into agreements with an Indian company (I Co) for providing services in the nature of publicity, advertisement, sales and reservation of rooms in the hotels of the I Co. It also permitted the I Co to use its brand name and trade mark as incidental to the main services provided. The I Co made a composite payment to the US Co at a percentage of total room sales and not with reference to any particular service. The issue before the ITAT was the taxability of the fees received by US Co from the provision of such services to the I Co. The US Co was a resident of USA within the meaning of article 4 of the double taxation avoidance agreement between India and USA (the treaty) and was eligible for the treaty benefits.

The high court in Mumbai has ruled that the Indian government can pursue its demand for capital gains tax (CGT) arising from Vodafone's purchase of a controlling stake in Hutch Essar in May. This could result in Vodafone paying up to $2 billion in taxes.

Peter Male Transfer Pricing Solutions, a UK-based boutique transfer pricing consultancy, has recruited Peter Male from Ernst & Young, where he spent 19 years. Recently, he was head of transfer pricing for the firm's Central and South regions before returning to the London transfer pricing team.

Gregory Broome has been recruited as a tax partner in the Washington DC-based international law firm Wilson Sonsini Goodrich & Rosati.

Edward Tanenbaum Industry focus approach to compliance The Large and Midsize Business Division (LMSB) of the IRS, which is responsible for examining businesses with assets of $10 million or more, has implemented an industry issue focus approach to compliance to improve consistency in the resolution of issues across industries. Compliance issues are identified by field agents through examinations, reviews of schedule M-3s and other sources. The issues are then prioritised and tiered. This strategy represents a shift towards centralisation of the resolution of issues that the IRS considers to be most prevalent and subject to the greatest compliance risk.

Bill Maclagan Kevin Zimka On September 21 2007, Canada and the US signed a new protocol (the protocol) to the Canada-United States tax convention (the treaty).

Juan Carlos Chavarría Costa Rica Costa Rican customs authorities have issued some resolutions initiating administrative procedures against customs' agents and importers that failed to comply with the requirements stated in the law for customs commercial invoices. For example, customs' agents did not provide along with the invoice, the translation of the list of the imported merchandise.

A new bill to limit tax planning in Portugal seeks to catch a wider group than first intended. Rogério Fernandes Ferreira of PLMJ explains how it will operate

Andrés Edelstein Ignacio Rodríguez The Argentine Government has been active during last 12 months enlarging the country's tax treaty network.