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  • The UK Chartered Institute of Taxation has produced a CD-rom guide for tax advisers setting up new businesses. The guide covers key issues in establishing a tax practice along with advice on marketing, recruitment and best practice through quality controls.
  • Bernard du Plessis: Appreciates working in a strong transactional practice South African law firm Sonnenberg Hoffman Galombik (SHG) picked up four senior PricewaterhouseCoopers tax specialists on December 1 2003. Their arrival follows a move to SHG by a 17-strong KPMG tax team in September 2002.
  • Spain only needs minor changes in its tax law to carry out Directives on taxation of savings income (2003/48/EC) and of interest and royalty payments (2003/49/EC).
  • The proposed section 482 services regulations change many aspects of the transfer pricing regulations for related-party services and the ownership of intangible property.
  • The Hong Kong SAR government is making agreements to avoid double taxation on income from international transportation operations with other countries and is developing Hong Kong as an international logistic centre. The latest agreement, on shipping operations, was signed with Norway in October 2003. It was the fifth of its kind and the second this year. Another was made with Germany earlier this year.
  • The UK will introduce a domestic transfer pricing regime on April 1 2004. Groups of companies face a huge compliance burden in documenting and justifying asset transfers within the UK. Companies will have a further consultation period until February 10 2004 to respond to the plan, which were confirmed in the pre-Budget report on December 10 2003.
  • Argentina has recently launched new thin-capitalization rules by reforming the Income Tax Law, effective October 22 2003.
  • Dennis G Dimagiba and Jehremiah C Asis of Quisumbing Torres (associated office of Baker & McKenzie) explain how to structure swaps, repurchase and stock lending agreements
  • The Korean National Tax Service (NTS) announced on December 10 2003 it will only conduct transfer pricing audits of foreign-owned companies when there is a clear indication of transfer pricing manipulation. The NTS plans to ease its tax audits on foreign companies to provide a more favourable environment for foreign investors.
  • On December 11 2003 the Mexican Congress began debating controversial reforms to gradually reduce corporate taxes to 30% by 2006. There were angry demonstrations over plans to slap an 8% tax on all goods that are now exempt from taxation, including food and medicine.