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Uruguay

The tax authorities need more rules to help them implement international transfer pricing standards, believe Rubén Hernández and Gabriela Villavicencio

August 31 2007

Mr Kleinbard goes to Washington

Kleinbard US Congress has chosen a corporate tax lawyer from Wall Street as the next chief of staff of the US Joint Committee on Taxation. Edward Kleinbard moves from a 30-year career advising institutional investors on M&A and financial products at Cleary Gottlieb Steen & Hamilton in New York to his new role in Washington on September 17.

August 31 2007

NTS announces tax audit directive for 2007

Henry An The National Tax Service (NTS) announced its tax audit directive for 2007 in July. The NTS indicated that the percentage of corporate taxpayers selected for tax audit would again be reduced, but that those selected for tax audit would be subject to more intense scrutiny. Specifically, the percentage of corporate taxpayers selected for tax audit would decrease from 0.9% in 2006 to 0.8% in 2007, which represents approximately 2,800 companies.

August 31 2007

Venezuela

Fernando Cruz and Lavinia Santos highlight how the tax authorities are increasing their scrutiny of transfer pricing arrangements

August 31 2007

Chile

Sergio Illanes, Miguel Zamora and Ana Paula Güitrón summarise the key points of the Chilean transfer pricing regime

August 31 2007

Central America

The countries of Central America will probably incorporate transfer pricing rules in to their laws in the near future, report Emilio Angeles and Alejandro Cervantes

August 31 2007

Case law against leveraged buyouts

Andrés Edelstein Ignacio Rodríguez The national tax court (Tribunal Fiscal de la Nación or TFN), which is not strictly speaking a court but an administrative tribunal specialised in the resolution of tax and customs matters, has recently issued an opinion challenging the deductibility of interest stemming from loans granted to an Argentine holding company to buyout an Argentine operating company. The acquisition was followed by a tax-free reorganisation (upstream merger) between the two Argentine entities.

August 31 2007

Sempra ruling ends divided tax bias

Sempra Metals won a landmark victory in the UK House of Lords in July. Clive Greenwood, joint head of partnerships and LLPs at Lewis Silkin in London, explains how a revenue interpretation was contrary to European law

August 31 2007

Learning to manage VAT risk

Christoph Schärer, in Zurich, and Harvey Mayne, in Frankfurt, from PricewaterhouseCoopers explains why VAT risk is a major threat to businesses in the EU

August 31 2007

US priority guidance plan receives mixed response

US treasury department The US tax authorities have released the list of issues they hope to produce guidance on by June 2008. The priority guidance plan released by the IRS and the Treasury department's office of tax policy on August 14 contains 303 projects.

August 31 2007

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