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The Asia Pacific region presents dynamic opportunities and unique challenges for global organizations. Business decisions involve complex issues; notably the tax implications.

Sue Bonney: "tax is now seen as it should be." Sue Bonney, the new UK CEO of KPMG's Tax and People Services practice, sees her challenge as securing more work and doing it faster. Bonney, the chief operating officer of the practice since 2003, replaces Colin Cook, who has become the firm's UK CEO, on August 1.

The Treasury Department and IRS, on July 31 2006, released the long-awaited regulations under section 482 on inter-company services transactions. The IRS also released an advance copy of Announcement 2006-50, providing a proposed revenue procedure that identifies particular services that are eligible to be charged at cost under the new regulations.

A combination of court decisions, tax treaty modifications and European Commission action have meant the government has had to work hard to maintain Luxembourg's friendly environment for investors, believes Keith O'Donnell of Atoz

The Chilean Tax Authority (SII) has now confirmed the importance of the concept of beneficial ownership regarding the application of Double Tax Convention (DTC), by the issuance of its Opinion number 1617/2006.

In a decision of May 31 2005, the Supreme Tax Court sided with the taxpayer in holding a long-standing group strategy to be a sufficient reason for the shareholding to qualify dividends to an intermediary holding company for treaty relief. This intermediary subsidiary had no staff of its own but was located in a country where the tax-haven parent had an active subsidiary The finance ministry has reacted to the case with the draft of a revised statute to tighten significantly the restrictions on treaty and EU directive shopping.

Aiming at transforming the Brazilian exchange market into a more competitive one, the government and the Brazilian Central Bank (BACEN) introduced early in 2005 significant changes to the exchange legislation. Yet, exporters and foreign investors were still expecting further changes, long announced by the Brazilian government. Some of these expected changes were introduced by Provisional Measure 315, which was issued on August 3 2006.

In its battle against value-added tax (VAT) fraud, the Belgian government has adopted a Program Bill that includes a measure according to which the co-contractor can be held jointly liable for the VAT due, on the condition that they knew or should have known that the VAT would not be paid to the Belgian treasury by the actual debtor of the VAT.

Australia and France have signed a new tax treaty to replace the existing treaty which was signed in 1976 and amended by protocol in 1989, and the Australia-France Airline Profits Agreement, which was signed in 1979.

The UK tax authorities have succeeded recently in obtaining bank information about taxpayers it suspects of tax evasion through their offshore arrangements. Andrew Watt of Chiltern analyzes what the developments mean for the future of tax investigations