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  • Letter from the editor
    International Tax Review, in association with KPMG, hosted its first Transfer Pricing Forum in Amsterdam on September 10 and 11. On the table for discussion were topics such as intangibles and intellectual property, e-commerce, APAs and dispute resolution, OECD and national developments, and practical transfer pricing strategies. The speaker line-up incorporated representation from in-house tax groups, professional advisory firms and law firms as well as the OECD.
    September 30 2001
  • What are the prospects for Japan’s consolidated tax system?
    Japan is holding industry-wide consultation on the implementation of a consolidated tax system to help boost its ailing domestic economy. Corporates should keep a close eye on the proceedings. By Yumiko Arai and Ken Huang, PricewaterhouseCoopers, Tokyo
    September 30 2001
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    How to raise the profile and mitigate the cost of IPT
    A recent ECJ ruling has thrown insurance tax into the limelight. This article examines issues from a UK perspective. By David Raistrick and Martin Ruffles, Andersen’s Indirect Tax Practice, Leeds and Manchester
    September 30 2001
  • McDermott achieves MDP status with landmark London hire
    International law firm McDermott, Will & Emery has recruited ex-PricewaterhouseCoopers senior tax partner, Guy Madewell, into its London tax practice. Madewell's appointment gives McDermott what it believes is the first multidisciplinary tax group of its kind in a London City legal practice.
    September 30 2001
  • US business calls for clarification on e-taxation
    The US is likely to take up proposed legislation to extend the moratorium on certain internet-related state and local taxes, despite opposition from a number of state governors. The existing three-year moratorium, imposed by the Internet Tax Freedom Act (ITFA) of 1998, is scheduled to expire on October 21 2001. However, a number of bills have been introduced that would extend the moratorium for varying lengths of time, including up to five years or maybe even permanently.
    September 30 2001
  • Boeing R&D decision creates split among US courts of appeal
    Creating a split among the US courts of appeal, the Ninth Circuit, in Boeing Co v US, validated Treasury Regulations section 1.861-8(e)(3) when it held that total research and development (R&D) costs must be allocated against export sales in computing the combined taxable income (CTI) of a FSC or DISC. The Boeing decision means that the appeals courts have now ruled once in favour of, and once against, taxpayers with regard to the proper allocation of R&D on unsuccessful or unexported products.
    September 30 2001
  • Latham broadens European offering
    Latham & Watkins and Stibbe Paris have combined, effective October 1, giving the firm 95 lawyers in Paris and more than 200 attorneys throughout Europe. The combined firm will be known as Latham & Watkins.
    September 30 2001
  • Transfer pricing in Europe: OECD versus local practice
    EU regimes are tightening up on their transfer pricing rules and regulations. The following provides a practical guide to some of the most recent changes. By Eduard Sporken, KPMG Global Transfer Pricing Services, Amstelveen; Alexander Vögele and William Bader, KPMG Frankfurt; Pascal Luquet and Sébastien Laisney, KPMG, Fidal Paris et International, Paris; and Elizabeth Musgrave, KPMG, Manchester
    September 30 2001
  • Substance over form in Latin America: myth or reality?
    Latin American regulatory regimes traditionally lack a general anti-avoidance provision permitting the tax authorities to challenge transactions on the basis of their actual economic substance. But recent changes allow the tax authorities to seek out the substance over the form of a transaction. Prepared by the Latin American Business Centre of Ernst & Young in Europe
    September 30 2001
  • Transfer pricing firmly on the global agenda
    As globalization continues apace, taxing jurisdictions worldwide are paying close attention to transfer pricing. This column summarizes recent international developments and changes in transfer pricing legislation. By Bill Dodge and Giovanni DiCenso, Deloitte & Touche, Washington, DC
    September 30 2001
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