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Ruth Donaldson Ernst & Young has established a dedicated international tax and transfer pricing practice focused on the middle market. It says there is growing demand for these services as clients become more global and tax laws become increasingly complex. The team will serve principally sub - FTSE 250 and AIM listed companies and large privates.

Sean Foley US Customs and Border Protection (CBP) recently issued an informed compliance publication (ICP) containing valuable guidance on related parties pricing (Determining the Acceptability of Transaction Value for Related Party Transactions). As part of the released guidance, CBP explicitly expressed its position on the use of Advance Pricing Agreements (APAs) and transfer pricing studies to support a Customs arm's length price, as discussed below.

Akio Takisaki The concept of triangular mergers has been introduced in Japanese Company Law in order to allow for merger transactions in which the shareholders of the acquired company will be compensated with shares in the parent company of the acquirer. As part of the 2007 tax reform, the requirements for tax-qualified types of consideration in mergers and deferral of capital gains or losses in shares of the disappearing corporation have been substantially revised. Now, in general, triangular mergers can be executed with no additional taxes.

Rajendra Nayak Ganesh Pai The Authority for Advance Ruling (AAR) in the case of In Re: Cargo Community Network Private Limited (2007) 289 ITR 355 recently examined the taxability of fees paid towards providing access to a portal. The applicant, a tax resident of Singapore, is a company engaged in providing access to an internet based air cargo portal in Singapore.

Nélio Weiss Philippe Jeffrey On May 25 2007 the tax authorities issued normative instruction (NI) 744 which set forth specific conditions that need to be fulfilled to allow Brazilian entities to claim a 0% withholding income tax rate on remittances to a foreign entity for promotion, publicity and market research expenses and leasing or rental of stands or space relating to the promotion of Brazilian products.

Peter Ackerman The Belgian federal government has decided to modify the corporate income tax treatment of car expenses for corporate tax payers (residents and non-residents).

Ian Tomlinson-Roe PricewaterhouseCoopers in Ireland has appointed four tax advisers to the partnership. Liam Diamond, who becomes a partner in the tax and inward investment practice, will advise US and Canadian multinational corporations on the tax and legal issues of investing in Ireland. He will also oversee PwC's Irish Tax Desk in New York.

By Jose Casas (Mexico), Marcelo Castillo (Argentina), Manuel Del Rio (Peru), Matthias Kaut (Germany) and Eduard Sporken (The Netherlands)

The complexity of tax regulation makes stringent demands on a company's tax department. The issue won't go away. Tax authorities are asking for more and more information and corporate executives are doing their best to comply.

The revenue generated by tax authorities across Europe has begun to rise again. New figures published by Eurostat, the EU's statistical agency show.