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  • The commissioner of taxation in Australia has told Foster's, a brewing company, that he may add to the tax assessment for Elders Financing Group, a subsidiary, to include the 1995 to 2004 tax years. Foster's tax bill for the subsidiary could now rise from A$237 million ($177 million) to A$379 million ($283 million). The parent company, which challenged the original disallowance of the tax assessment in May, said it will continue to contest the Australian Tax Office's opinion.
  • The Corporate Tax Alliance will comprise 13 tax specialist firms from Europe, three from Asia and the Americas.
  • Hans Olav Hemnes Morten Beck The Ministry of Finance is now preparing a green paper on transfer pricing documentation rules. This is expected to be published later this autumn. It is anticipated that the proposed legislation will be in line with the EU Transfer Pricing Documentation Code of Conduct.
  • Multinational enterprises often allocate the ownership of IP among their group companies with more regard to legal than to tax issues. Karen Hughes and Domenico Borzumato consider how companies can achieve greater tax efficiency when managing their IP internationally
  • Hanno Berger and Jens Kleinert explain how European law prevents Germany from denying cross-border fiscal unity
  • Deciding on which valuation system would prevail would be the issue if VAT, Customs and transfer pricing were to be integrated, believe Monique van Herksen, Folkert Idsinga and Gooike van Slooten of Baker & McKenzie
  • The European Court of Justice's (ECJ) ruling in Cadbury Schweppes is set to force the UK and other EU member states to change their laws on controlled foreign companies (CFC).
  • Hong Kong: First port of call for investors into China? The double taxation agreement (DTA) between Hong Kong and China is expected to create opportunities for Hong Kong investors. The DTA, signed on August 21 between the HKSAR government and the Central People's government will offer Hong Kong investors protection against passive income, and further enhance the jurisdiction's place as a stepping stone for investors into China.
  • The recent GlaxoSmithKline (GSK) settlement with the IRS and taxpayer's continuing problems with intangibles were two of the issues that grabbed attention at International Tax Review's sixth annual Global Transfer Pricing Forum in London
  • Welcome to the new International Tax Review! New in the sense that there's more colour and the look is fresh and different. But the magazine is not changing its aim of bringing the most up-to-date information on international tax to executives at multinational companies around the world.