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  • By Nam Nguyen and Carlo Navarro, Ernst & Young, Vietnam
  • By John Donaldson and Andrew Riordan, CRA International, Melbourne
  • Tax authorities are under pressure to reduce the gap between the amount they know they should receive and the revenues that they actually recover. Direct taxes have been feeling the squeeze for sometime. Now it's indirect taxes' turn. Officials are targeting all transactions to ensure they are getting what is due to them in indirect taxes. Taxpayers need specialist, world-class advice on how they should conduct their business to achieve the greatest efficiencies in indirect taxes.
  • By Jesper Solgaard and Senaka Senanayake, Ernst & Young, Singapore
  • By Shyamal Mukherjee and Sanjay Tolia, PricewaterhouseCoopers
  • Roberto del Toro Marco Nava A basic rule that taxpayers must follow in order to apply a benefit contained in a tax treaty for the avoidance of double taxation is to demonstrate its tax residency. In this connection, there was no specific guidance for Mexican taxpayers to obtain a Mexican tax residency certification.
  • Jan Becker Sebastian Hölscher The Annual Tax Bill 2007 will introduce a switch-over clause into German tax law denying a treaty exemption to German residents if, due to differing legal definitions of income, the other country either does not tax the respective income at all, or only by withholding. The same will apply where the other country does not tax the income because it does not see the recipient as its own tax resident.
  • The new double tax arrangement between mainland China and Hong Kong applies to passive income, unlike its predecessor. It also opens up some planning opportunities for Hong Kong companies, reveal Raymond Wong and Guy Ellis of PricewaterhouseCoopers Hong Kong
  • Having clearly defined functions within a company's tax department is crucial to a successful transfer pricing policy. The next step is implementation explains Herve Bidaud of Hogan & Hartson and Emmanuel Llinares of NERA Economic Consulting
  • Type of deal Valuer Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition £1.4 billion ($2.63 billion) Three Delta (UK) Four Seasons Healthcare (UK) Herbert Smith (UK) Macfarlanes (UK)