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Three new tax partners, all from Arnold & Porter, have joined the Washington, DC office of McDermott Will & Emery.

The eventual outcome of the Textron case concerning the disclosure of workpapers during an audit could have implications for all companies that have to comply with the FIN 48 accounting standard

The British Institute of Directors (IoD) has called on the UK government to simplify its taxation system

The role of head of an in-house tax department is becoming an increasingly complex and challenging one to take on. Long hours, resource and talent shortages and ever-changing legislative landscapes are but a few of the challenges

Risk is something that goes hand in hand with the oil and gas industry. Militants' guns in Nigeria, political tensions surrounding reserves in Russia and Venezuela and production uncertainty that paticipants must accept: the market faces it all. There is another challenger - the tax authorities

Dirk Van Stappen In 2004 the Belgian legislature introduced the arm's length principle in Belgian tax law through article 185 paragraph 2 of the Belgian Income Tax Code (BITC). Practice reveals that article 185 paragraph 2 BITC gives also the possibility to claim exemption of excess profits by means of an advance ruling or APA with the Belgian tax authorities. As such the provision offers planning opportunities from a transfer pricing point of view. The basic idea behind this planning opportunity starts from the fact that a Belgian company, being member of a multinational group, usually benefits from a whole set of advantages resulting from its membership of the multinational group (for example know-how, reputation, research, economies of scale and synergies.) for which it is often impossible to determine an appropriate arm's length remuneration as all group entities are benefiting from it and the underlying mechanics are often complex and thus hard to unravel.

Neil Wilson Division 7A of the Income Tax Assessment Act 1936 (ITAA 1936) applies to certain loans and payments by a private company to its shareholders (and their associates) and to the forgiveness of a debt owing by any such person to the private company. The words loan and payment are defined terms, and extend beyond the ordinary meaning of these words such that, for example, the provision of property by a private company may in certain circumstances be treated as a payment.

KR Girish and Rohit Jain, of KPMG in South India, review the impact of key transfer pricing decisions for multinational companies

High taxes for Uganda's telecoms companies have been attacked as inefficient.

James MacLachlan and John Fairley of Baker & McKenzie examine the UK government's thinking on the taxation of foreign profits