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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

Richard J Vann of Greenwoods & Freehills shows where the tax opportunities lurk under the latest US-Australia double tax agreement

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

UK government proposals to reform the corporate tax system could be damaging for domestic businesses. The government plans to introduce a costly domestic transfer pricing system and impose tax changes to finance leasing. Companies have until November 3 2003 to respond to the Corporation Tax Reform Consultation published on August 12 2003.

The Italian tax authorities (ITA) have revoked, with ruling 159/E of July 25 2003 (the New Ruling), their previous ruling dated December 13 2000 (the Previous Ruling). The Previous Ruling addressed a transaction (the Share Exchange) whereby an Italian company (the Contributing Company) transferred to a beneficiary company resident of a different EU Country (the Beneficiary Company), the controlling stock of another company (the Controlling Stock), solely in exchange for the Beneficiary Company's shares (the Shares).

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:

On July 9 2003 the Brazilian Congress approved a Bill, originally from 1989, relating to the application of the municipal services tax (ISS). The Bill brought important changes to the existing legislation and expanded the original list of services subject to the tax. The newly-added services are mainly relating to IT and banking services. The new project is expected to increase the total of ISS collected by municipalities from R$8 billion ($2.7 billion) to R$15 billion ($5 billion) within the next three years.

Irma Johanna Mosquera Valderrama explains what the reforms will mean for companies operating in the country