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PKF is an international association of specialist tax, accounting and business consulting firms, advising clients in diverse industry sectors, through a network of 240 member firms in 114 countries. The PKF Australian Tax Practices have highly trained tax consulting teams with expertise in all areas of corporate and personal taxation, with particular specialist skills in corporate restructures, tax audit management, international tax, expatriate taxes, Captial Gains Tax, Goods and Services Tax and research and development concessions.

The German government approved on August 13 2003 a draft tax Bill that contains, among other measures, a completely redesigned set of thin-capitalization rules that are intended to be compatible with European law. The European Court of Justice (ECJ) held in its December 2002 Lankhorst-Hohorst decision that the existing thin-capitalization rules violate EU law. The ECJ's primary objection to the existing rules is that they apply primarily to foreign shareholders of German corporations, placing foreign EU shareholders at a disadvantage compared with similarly-situated, German-resident shareholders. While the German government was expected to respond to Lankhorst-Hohorst by extending the thin-capitalization rules to domestic shareholders (and their related parties), many tax professionals were nonetheless astonished by the sweep of the new proposal.

Tax adjustments relating to the remuneration of inter-company administrative, technical and commercial support services are as frequent as the performance of such services is common.

UK plans to extend transfer pricing and thin-capitalization rules to domestic transactions

Heather Meeker of Tomlinson Zisko considers tax strategies for hi-tech firms with high-value intellectual property

The OECD consultation on the use of comparable company benchmarks in transfer pricing raises fundamental issues about traditional pricing methods and approaches argue Ernst & Young's Bob Turner, Ken Okawara and Robert Miall

Type of deal

Baker & McKenzie's A Duane Webber, Robert S Walton and George M Clarke analyze the implications of the crackdown on tax shelter transactions

On June 11 2003 the Ministry of Finance in Japan and the Treasury Department in the US announced that Japan and the US have reached an agreement in principle on the text of a new tax treaty between Japan and the US. The proposed new treaty will make an overall revision of the treaty between the two countries, which was put in place in 1971. The new treaty, while taking the OECD model treaty as a basis, will reflect the importance of the economic relationship between the two countries as strategic partners, promote investments between them, and at the same time will prevent improper exploitation of the treaty.

A circular issued in April 2003 clarifying the implementation of China's new tax-collection law clarifies the situations in which the statute of limitation on transfer pricing adjustments can be extended to ten years from the normal three years. These include instances where: