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  • Motorola, the multinational telecomunications company, could face an extra tax bill of up to $500 million after investigations by the US IRS into its tax returns for 1996 to 2000. A further probe for the years since then is still under way. The investigations centre on the company's transfer pricing practices.
  • The Supreme Court of India has held that business income and capital gains earned by an Indian resident from immovable property in Malaysia cannot be taxed in India under the India-Malaysia tax treaty
  • The Indian Central Board of Direct Taxes (CBDT) released a draft circular last Mondaythat refines the hazy definitions over the taxation of business process outsourcing (BPO) by multinational companies
  • Donald Korb, chief counsel of the US IRS, on August 13 2004 hired a senior counsel to focus on eradicating abusive tax transactions. Jonathan Zelnik will work with the IRS and the Department of Treasury's office of tax policy to identify, analyze and issue administrative guidance to address abusive transactions.
  • The Chinese State Administration of Taxation (SAT) has issued guidance on how the country should select companies for fiscal year 2004 transfer pricing audits. The circular instructs local tax officials to select at least one suspected big target company and report it to the SAT before August 31 2004.
  • Section 245 of the Income Tax Act (the Tax Act), enacted in 1988, contains a general anti-avoidance rule (the GAAR) that incorporates a modified business purpose test into Canadian tax legislation
  • Almost all of Germany’s 16 regional Länder have rejected calls to centralize tax collection in the country
  • A Latvian with a reputation for euroscepticism will become the commissioner for taxation and customs union when the new EU Commission takes office on November 1 2004
  • Tonucci, the Italian law firm, will increase its tax capability on September 1 2004 when it will merge with Studio Grimaldi & Associati, a renowned tax boutique. The move will see the boutique's 10 tax professionals, who specialize in domestic and international tax planning, join Tonucci under the leadership of Piero Alonzo and Gian Marco Committeri.
  • Last Tuesday a team of five former Andersen partners left Ernst & Young in Luxembourg to join a team of 30 to set up a high-end, new international tax firm called Atoz