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The national tax administrations have been encouraging taxpayers to obtain advance pricing arrangements (APA) with a notable emphasis on bilateral APAs. This is to ensure the appropriate application of the transfer-pricing rules and regulations, reduce administrative costs relating to transfer-pricing taxation and provide predictability for corporate management. Recently, bilateral APAs processed between Japan and Asia-Pacific countries have been increasing. In 2003 there were 18 cases, which was more than the 16 with the US. On April 28 2005, an amended circular relating to the transfer pricing administrative guidelines was issued noting further clarifications to the APA programme.

Sed Crest finds out what is troubling tax executives in Asia and why they want a closer relationship with their tax advisers

A June 2005 memorandum of understanding has resolved some of the awkwardness in Canada-US mutual agreement procedures. Now the challenge is to put the agreement into practice, says Janice McCart of Blakes Cassels & Graydon

The European Court of Justice went against the opinion of the advocate-general on the most-favoured-nation principle in the D case. The judges should use pending cases to elaborate on their decision, argues Frederik Habers of Nauta Dutilh

The Brazilian tax authorities issued Provisional Measure 252 (PM 252) on June 15, which granted specific tax incentives and created special tax regimes. These incentives were granted mainly to exporting local entities and also to the IT industry. The main changes/incentives set forth in PM 252 are summarized here:

Only a few months after the conclusions of Advocate-General Maduro in the "the case of the year" (Marks & Spencer), the full court of the ECJ gave the member states some time to breathe again in the battle between international tax law and EU law. In the D case it decided on the application of the most-favoured nation doctrine to double tax treaties. This decision will be known as one of "these cases" setting the rules of international taxation in the EU.

Arecent Supreme Court decision represents a serious reverse for Argentine taxpayers that have been claiming during the last three years for the re-enactment of the inflation adjustment for income tax purposes.

Following the publication in the Italian Official Gazette of July 4 2005 of the Decree of Ministry of the Economy of June 23 2005, the new tonnage-based corporation tax envisaged by articles from 155 to 161 of the Italian Tax Code (the Tonnage Regime) has become effective - for calendar-year taxpayers - as from January 1 2005.

Martin Zetter, now of LECG, set up and managed the transfer-pricing function for one of the largest financial services multinationals for five years. Here he gives some pointers on getting the most out of an in-house transfer pricing team.

Arnold van der Smeede and Adam Sibarani of Spigthoff discuss the proposals to change the Dutch corporate tax act which were announced at the end of April