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  • Horacio Dinice and Manuel Diskenstein of Deloitte explain how the burden of gathering transfer-pricing information falls squarely on the taxpayer's shoulders
  • Akio Takisaki The Japanese tax system basically provides for two different kinds of tax credit: direct foreign tax credit and indirect foreign tax credit.
  • Lorenz Bernhardt Jobst Wilmanns Following the transfer pricing documentation rules in 2005 and the new arrangements for advance pricing agreements this October, the finance ministry has turned its attention to examining the substance of specific transactions. The first item on the agenda is the transfer of functions abroad, prompted by fears, real or imagined, of multinationals shifting as much as possible of their business to low-cost, low-tax countries as a deliberate policy of avoidance.
  • Chiltern has appointed Shiv Mahalingham as transfer pricing head. Mahalingham was at Ernst & Young before joining Chiltern.
  • Lauren Byrne, formerly of Ernst & Young, and Martin Williams, who was with PricewaterhouseCoopers, have joined the New York tax group of Alvarez & Marsal as senior directors.
  • Levy Mwanawasa, Zambia's president, has said that the 2007 budget will set out tax reforms. Companies investing in rural areas, in agriculture, and employing women and youths are to benefit from tax breaks.
  • Robert Fore has become assistant vice president global taxation at PMI Group. Fore was previously director of accounting at CMG Mortgage Insurance Company.
  • Peter Corcoran, previously international tax leader at Deloitte's Canadian practice and an ex-global leader of international tax services, has left to become executive vice president at automotive company Magna.
  • Following the introduction of mandatory e-filing of corporate returns, the Indian finance ministry said that the deadline for the filing of business income tax and fringe benefit returns would move from October 31 to November 30.
  • Bertie Ahern, the Irish Taoiseach, wants Northern Ireland' s corporate tax rate to match the 12.5% rate in the Republic. Ahern's calls follow pleas for a rate cut made by Ian Paisley, leader of the Democratic Unionist political party, and prominent businessman Sir George Quigley.