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  • After years of debate, several tranches of legislation and many delays, the implementation of Australia's new tax consolidation regime is upon us. However, many businesses are entering the new system in a state of tax reform fatigue - with many organizations finding that the implementation is taking longer and involving more resources than expected.
  • Roberto Haddad of Branco Consultores gives a thorough run-down of how the country taxes imported services is becoming more complicated
  • José María Cusí and Roberto Grau of Clifford Chance explain how to benefit from the issue of preferred shares and debt instruments under the new Spanish regime
  • Martin Bünning of Allen & Overy looks at the elements of the tax package that are relevant for international business transactions and are the most likely to be adopted
  • The government of Turkey has released its draft of the Frame Law on State Assistance in Investments, which provides for income and corporate tax exemptions for up to 10 years. The Bill targets foreign investment particularly in the textile and iron and steel sectors.
  • Andrew Packman and Diarmuid MacDougall of PricewaterhouseCoopers explain R&D incentives, including the policy background to recent changes in the UK, the approach of other countries and the issues that businesses will need to address
  • Non-US companies investing in the US through multiple chains of ownership should be aware of certain potential US tax benefits in cases where they have a financially troubled US subsidiary. Sometimes difficulties arise inasmuch as the loss occurs in a less profitable chain of subsidiaries and cannot be used to offset income of a more profitable chain of subsidiaries.
  • James P Fuller of Fenwick & West explains how the US Internal Revenue Service's proposed new transfer pricing methods for services transactions would work
  • Attracting more than 200 tax professionals, representing more than 50 multinationals and with delegates coming from 22 different countries, the Transfer Pricing Forum 2003 ran for two days from September 22 and 23 in the heart of New York at Essex House on Central Park. The third time that International Tax Review has hosted the event in association with KPMG, the highlights from this year's forum included a candid address from Hal Hicks, Associate Chief Counsel (International) at the US Internal Revenue Service, analysis of the new services regulations and sessions on transfer pricing strategies in practice and the commercial implications of transfer pricing.
  • The US Treasury and the Internal Revenue Service issued final regulations on the tax treatment of stock-based compensation under the related-party transfer pricing rules governing qualified cost-sharing arrangements on August 25 2003.