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In the first in a new quarterly series looking at global transfer pricing developments, the following article tracks recent changes in Europe, Asia-Pacific, Latin America, North America and Africa. By Bill Dodge and Giovanni DiCenso, Deloitte & Touche, Washington, DC

Belgian companies wishing to motivate their employees through participation schemes now have the backing of the new Participation Law to facilitate their efforts. By Marc De Munter, Freshfields Bruckhaus Deringer, Brussels

Future pension provision for an ageing population is a key consideration of this millennium. The European Commission is attempting to resolve the issue, but its inevitable failure to align the conflicting interests of EU member states has led it to rely on the ECJ, rather than directives, to force the pace of change. By Travis J Barker, PricewaterhouseCoopers, London

Clifford Chance has recruited tax partner Thierry Blockerye from Pricewaterhouse-Coopers to establish and head up a tax practice in its Brussels office. Blockerye, who specializes in corporate, M&A and real estate tax law, joined the firm in June, bringing with him a team of assistants. Blockerye has worked at PricewaterhouseCoopers in Brussels since 1988, where he was made a partner in 1996. He has established a reputation in real estate tax in particular, and advises many Belgian and international institutional property investors and developers.

Tax laws on investment funds in some of Europe's most dominant economies could be in breach of European law, preventing the development of a regional market

Ned Maguire, an international tax partner with Deloitte & Touche in Washington DC, has been selected to serve for two years as a member of the government/industry technical advisory group (TAG) to the Committee on Fiscal Affairs of the OECD on the taxation of electronic commerce. The OECD Committee has been responsible for formulating and updating the OECD Model Income Tax Convention, and authoritative technical reports on transfer pricing and other international tax issues.

Two Palo Alto Square

Determining the profits attributable to a PE is poorly explicated in practice. The OECD has drafted a proposal to clarify matters. By Philip R West, Andersen Office of Federal Tax Services, Washington, DC, and Robert Janukowicz and W Anne Jie, Andersen, New York

Foreign investors looking to use the beneficial ownership provisions of Russian tax treaties are up against a tradition of inconsistent application and poorly developed concepts. No guarantees are on offer, and the present round of tax reforms offers little hope for improvement. By Victor Matchekhin, Linklaters, Moscow

Tokumei kumiai arrangements continue to be a versatile planning technique for achieving a wide range of business and tax structuring objectives. This article looks at their use in Japan, and at the increase in tax audit scrutiny of TK arrangements. By Dean A Yoost and Todd Landau, PricewaterhouseCoopers, Tokyo and New York