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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.

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

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

Owen Arthur, prime minister of Barbados, has called on the UN to establish rules to govern cross border taxation issues.

Australia and Japan have agreed to revise a bilateral tax treaty in a bid to promote mutual trade and investment.

Representative Lloyd Doggett wants to alter significantly the way that US withholding taxes are computed on deductible payments made to foreign persons. Mike Patton, principal at Ernst & Young Los Angeles, explains why Doggett will not succeed