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In the course of 2002 few changes were made to the Brazilian transfer pricing legislation; the main one being the expansion of transactions subject to transfer pricing regulations. Following the enactment of Law 10451 (May 2002), transactions undertaken between unrelated Brazilian individuals or legal entities and foreign individuals or legal entities resident or domiciled in a country in which local legislation allows corporate ownership secrecy are subject to Brazilian transfer pricing regulations.

With its tax rate of 12.5% and a tax system that since 1997 has aimed to make securitization deals effectively tax-neutral, Ireland is already a popular onshore location for securitization. But changes announced in its Finance Bill in February 2003 should make the country even more attractive. The Bill announced changes to simplify and update the securitization rules to take into account a much wider range of transactions. It is due to be enacted by April 4 this year and changes are possible until then but it will be effective from February 6.

The region's ever-expanding tax treaty network is providing new tax-strategy opportunities. Nicasio del Castillo, Jorge A Gross, Eduardo Pupo and John A Salerno of PricewaterhouseCoopers show where

There seems to be no escape for the big accounting firms in the US. Just after their fears were alleviated by the final wording of the Sarbanes-Oxley Act, which seemingly guarantees that they can continue providing tax services to audit clients, they face another attack. This time, the US government is cracking down on tax shelters offered by accounting firms and the big four, and other professional services firms are hitting the headlines once again.

Attempts to introduce a new income tax in Bolivia collapsed after violent strikes left more than 10 people dead and many more injured in the capital city, La Paz. The Bolivian president Gonzalo Sanchez, announced that he was abandoning his Budget in light of the violent demonstrations in the city. The country descended into violence after the government announced its intention to bring in a tax of 12.5% to reduce the budget deficit.

The country's Ministry of Finance and the Chamber of Tax Advisers are testing electronic VAT returns. They are looking at issuing, filing, receiving and recording the forms electronically with the system due to be fully active in March this year.

The SEC is suing KPMG and four KPMG partners including the head of the firm's department of professional practice for fraud. The charges relate to KPMG's audits of Xerox from 1997 to 2000.

Proposals in Japan to allow the use of foreign company shares in stock-for-stock deals with domestic entities will be ineffective because the government will not remove prohibitive tax burdens.

Ernst & Young has successfully struck out a £2.6 billion claim against it by Equitable Life and the judge described Equitable's alternative bonus claim as 'seriously flawed'.

Transfer pricing has been one of the most talked about areas of tax work in recent years and so far it has stayed firmly in the hands of the professional services firms. The big four have been able to make full use of their international networks in restructuring multinationals' supply chains and advising on the full range of transfer pricing services. Very few other firms have been able to compete on such a scale.