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Transfer Pricing Associates, an international boutique headquartered the Netherlands, has set up operations in the US, France, Germany, Japan, Switzerland, Australasia and South Africa.

Jill Weise, a former New England transfer pricing leader and firm director at Deloitte in Boston, has left the firm to join CRA International.

The IRS has issued an audit checklist to guide IRS examiners when they audit cost-sharing arrangements (CSA). The audit checklist contains a detailed list of documents that IRS examiners should request on audit and provides extensive instructions on how examiners should approach common audit issues, such as the valuation of buy-ins and the treatment of stock options.

Wilhelm Haarman: has no plans to retire Wilhelm Haarmann, a founding partner of German law firm Haarmann Hemmelrath, has decided to leave the firm after internal disagreements about its future direction.

The Internal Revenue Service (the Service) has issued final and temporary regulations (the New Regulations) on the withholding obligations of a partnership under Internal Revenue Code (IRC) section 1446 with respect to US business income allocable to a foreign partner. They are generally effective for partnership taxable years beginning after May 18 2005 but partnerships may elect to apply them to partnership taxable years beginning after December 31 2004.

Last year, new tax disclosure rules were introduced in the UK which obliged promoters and, in certain cases, users of tax planning arrangements involving financial products or related to employment to notify details of the arrangements to HM Revenue & Customs. These rules have been extended to stamp duty land tax (SDLT) – a real-estate transfer tax. The new rules have been drafted as an extension of the rules in relation to financial products/employment (for more details of these, please see our international updates for June 2004 and November 2004).

The use of trusts in South Africa has long been a common feature of commercial life. South African trusts are, for all practical purposes, identical to the trusts to be found in jurisdictions that have English law as their basis. Even though South African trust law has been influenced in a number of respects by English law and the development of trust law in those jurisdictions, the law upon which trusts are based in South Africa is different to the basis in English law (remember that South African law is Roman-Dutch, though in relation to commercial aspects, with a great deal of English law influence).

Qatar has announced the establishment of the Science and Technology Park (STP) and Qatar Financial Centre (QFC) as Qatar's first tax-free zones. By providing no-tax environments, Qatar is hoping to attract multinational foreign companies in the technology and financial sectors.

Recent significant changes to the Russian Tax Code regarding profit tax of organizations were introduced by the federal law signed by President Putin on June 6 2005.

Acourt in Luxembourg has ruled that capital gains derived by a Luxembourg corporation from the disposal of shares in a French civil company having opted for French corporate income tax do not qualify for the Luxembourg participation regime.