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  • By Shyamal Mukherjee and Sanjay Tolia, PricewaterhouseCoopers
  • By John Donaldson and Andrew Riordan, CRA International, Melbourne
  • 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
  • Klaus Goutier The need to ensure independence of tax services from legal advice is what led the entire tax group of German law firm Goutier & Partners, to separate from the firm and merge with other professionals to form ArAnTax, a tax boutique,. "ArAnTax is a fantasy name" says partner Klaus Goutier, "it comes from the thought of art and tax".
  • Henry An Jin-Young (David) Lee The Korean transfer pricing regulations are contained in the Law for the Coordination of International Tax Affairs (LCITA), which has been in effect since January 1 1996. The Ministry of Government Legislation announced amendments to the LCITA on May 24 2006 and underlying Presidential Enforcement Decree (PED) on August 24 2006.
  • Peter Dachs The general-anti-avoidance rule (GAAR) is contained in section 103 of the Income Tax Act. The present test has essentially four requirements that must all be fulfilled before there is tax avoidance.
  • The US Internal Revenue Service (IRS) and Glaxo-SmithKline's (GSK) $3.1 billion settlement marks an increased focus on transfer pricing enforcement from the IRS, and serves as a warning to taxpayers on both sides of the Atlantic. The settlement, which applies to the company's US tax returns from 1989 to 2000 is the largest ever single payment to resolve a tax dispute in the US. The IRS' original claim against GSK was for $11.5 billion for 16 years of tax accounts between 1989 and 2005.
  • Tax authorities fear they are losing millions from arbitrage. The worry means that forms of structuring which were considered legitimate are now under suspicion. International Tax Review examines an increasingly confused area of planning
  • By Alejandro Gómez Rutmann and Iván S Gutiérrez Lombardo, Deloitte
  • By Luis Liñero, Deloitte