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Julian Robertson-Kellie and Shiv Mahalingham of Ernst & Young discuss how to combat value leakage that is attributable to inadequate transfer pricing polices for intra-group transactions and whether traditional transfer pricing policy is appropriate today

A recently issued notice had spurred development of China's APA programme. The programme can be useful to address not only cross-border but also intra-China transfer-pricing issues, explain Spencer Chong and Qisheng Yu of PricewaterhouseCoopers

David Rivkin's guilty plea in the case of bogus tax shelters involving former KPMG staff and bankers and lawyers, was "made out of fear and a lack of resources rather than any real guilt," according to Stanley Arkin, a lawyer for Jeffrey Eischeid, former head of KPMG's innovative strategies group. Eischeid goes on trial in the case with 17 ex-colleagues later this year.

Canada's new minority government is unlikely to introduce any dramatic policy shifts so its impact on international tax issues is likely to be limited, though plenty need its attention, explains Stephen Bowman of Bennett Jones

The chairman of the Senate Finance committee, which is responsible for tax writing, said that tax reform would be delayed until next year. Chairman Charles Grassley also said that policy makers should try to find a way to cut the corporate tax rate, which at 40% is one of the highest in the world.

Tax accounting, transfer pricing and having enough people to do the job are some of the challenges facing the leader of a company's tax department today, Paul Morton of Reed Elsevier tells International Tax Review

Taxpayers should maintain accurate transfer pricing documentation to avoid attention from the revenue authorities, believe Vispi Patel and Sanjay Kapadia of RSM & Co

Taxpayers should address the tax issues relating to outsourcing early so they get the benefit of efficient services in a cost effective manner, believe Samir Gandhi and SP Singh of Deloitte Haskins & Sells

In response to taxpayer requests for guidance on the US tax treatment of cross-licence arrangements, the Internal Revenue Service (IRS) recently published Notice 2006-34, 2006-14 IRB 705, (the Notice), seeking information from taxpayers and practitioners on the substance of such transactions. Cross-licensing transactions are commonly entered into between parties who each own intellectual property (IP), often patents, and who wish to secure specified rights with respect to the IP owned by the other party. The motivations for entering into these arrangements vary, including, use of the other party's IP to develop a new product and averting potential infringement lawsuits that may arise from the exploitation of one's own IP (for example, licensing rights to a similar technology to avoid an infringement claim with respect to one's own IP).

Ricardo Escobar has become the first practising tax lawyer to become head of Chile's tax authorities (IRS) since the country returned to democracy in 1990.