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Keith O'Donnell of Atoz and Franck Llinas of Arsène -Taxand examine the impact of a ruling which allows Luxembourg to seek revenue from French real estate structures

Gabriela Villavicencio and Armando Cabrera look how Argentina's transfer pricing rules have developed since their introduction in 1998

Monaco The OECD has removed two jurisdictions from its harmful tax practices list. Liberia and the Marshall Isles were taken off in the space of a month.

The government in Seoul has decided to extend the period of a corporate tax cut - for larger foreign companies - from five to seven years in order to promote foreign investment in the country's free economic zone.

A dizzying pace of growth is one of the main challenges for Asia's tax directors. Our cover feature this month identifies the 10 most admired tax directors in the region. We also examine the central messages emerging from regional tax directors.

Richard Murphy argues that the news that Ireland is to review its corporation tax policies is welcome, but only if the parameters for debate are set appropriately.

Stephen Nelson Our last article addressed processing and assembly arrangements and permanent establishment issues under the recent PRC State Administration of Taxation (SAT) notice (Guoshui (2007) 403) on the China-Hong Kong double tax arrangement (DTA). We now continue our discussion of issues arising from the notice, focusing on the interpretation of capital gains exemption.

Antonio Ruiz On February 3 2004, the governments of Costa Rica and Spain signed a treaty for the avoidance of double taxation and prevention of fiscal evasion, on income and equity taxes (the treaty). This bill is under scrutiny by the Costa Rican Congress and it is expected to be approved in the following months.

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.

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