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September 30 2005

Outsourcing in the financial services sector and VAT

Keith Loughman (KPMG in Ireland), Philippe Breton (Fidal International), David Fownes (KPMG in the UK) and Rick Franke (KPMG in the Netherlands) examine how VAT affects outsourcing initiatives in the banking, asset management and insurance sectors

September 30 2005

Taiwan - Transfer pricing rules begin a new era for Taiwan's tax system

By Lorene Chen, KPMG in Taiwan

September 30 2005

China - Racing to catch up with global transfer pricing standards

By Jon Eichelberger, Marc Levey and Peng Tao, Baker & McKenzie

September 30 2005

VAT and avoidance post Halifax

A recently published opinion of the EU's Advocate General clarifies EU anti-avoidance law and the principle of so-called abuse. Amanda Brown of KPMG in the UK explains the Advocate General's reasoning and explores its implications for taxpayers

September 30 2005

Editorial

Enforcement is the name of the transfer pricing game in Asia right now. After going to much trouble to institute their own transfer pricing rules, jurisdictions in the region have set about ensuring that those rules are being adhered to. In countries, such as Australia, which have had rules for a little longer, the tax authorities continue to refine their enforcement techniques, including litigation, in an attempt to get taxpayers to pay their fair share of tax from related-party transactions.

September 30 2005

Creating value in a changing regulatory environment

Tax systems are struggling to keep pace with the speed of business change. Graeme Ross and John Bain of KPMG in the UK argue that taxpayers and tax authorities have a common interest in developing and maintaining modern tax systems

September 30 2005

Employee share plans become more flexible

The enactment of two resolutions in March 2005 by the National Monetary Council of the Central Bank of Brazil (BACEN) brought significant changes to the Brazilian exchange market and the foreign exchange control regulations. The resolutions also lifted many of the restrictions imposed on transfers of funds used to acquire shares of foreign entities.

September 30 2005

New transfer pricing audit centre requests information

The Belgian tax authorities manage a wide range of provisions, enabling them to investigate transfer prices and to adjust the tax base in case the arm's-length principle is not respected. They also published in 1999 an administrative circular letter, explaining to tax inspectors when and how a transfer pricing audit should be performed.

September 30 2005

How foreign-resident trust beneficiaries can avoid capital gains tax

The Australian Taxation Office (ATO) has confirmed in Interpretative Decision ATO ID 2005/225 that a foreign-resident beneficiary of a fixed trust is able to disregard certain capital gains attributable to it and in respect of its interest in the fixed trust even if the underlying capital gains tax (CGT) event happened to the trustee before March 21 2005.

September 30 2005

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