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Lewis Fernandez and Susan Stanley have joined PricewaterhouseCoopers as directors in the Washington National Tax Services' Internal Revenue Service (IRS) service team.

Glen DeSouza Baker & McKenzie will be expanding its transfer pricing capabilities in China by entering into an exclusive alliance with TP Management Consulting (TPMC) in Shanghai.

In view of increasing mergers and acquisitions undertaken by Taiwanese corporations for reorganisation purposes, the Ministry of Finance has recently released the tax ruling, Tai-Tsai-Shuei #9604545320, on October 3 2007. The tax ruling stipulates that when a company transfers its independently operated business to its 100% owned existing or newly incorporated subsidiary in exchange of the subsidiary's newly issued shares according to the Enterprise Merger and Acquisition Act and under the principle that the spin-off is not used as a tax avoidance device, the spun-off assets can be transferred at their book value, as the cost of share acquisition, to determine the property trading income/loss and the corresponding tax liability.

Diego Rodríguez As of today there are 68 tax treaties in force that have been signed by Spain. There are also 15 additional tax treaties that have already been initialled, signed or are awaiting parliamentary approval.

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.

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.

Tokyo The number of mutual agreement procedures (MAP) involving an advance pricing agreement (APA) in Japan has increased by 600% in the last decade.