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Does article 17 of the OECD model convention have its basis in outdated and discriminatory assumptions about artistes and athletes? Hold on to your hats for a whistle stop tour of its development, its lack of fit with the modern world and reasons for its repeal. By Joel Nitikman, Fraser Milner Casgrain LLP, Vancouver

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

US law firm Atheimer & Gray has established a tax group in London by poaching the head of tax from Fox Williams. Vishvas Kanji is joining Atheimer & Gray in June this year, having been a partner at Fox Williams since 1996.

KPMG Meijburg in Amsterdam has expanded its transfer pricing group by hiring a senior manager from PricewaterhouseCoopers. Eduard Sporken joins the firm on June 1. Sporken had not been thinking of leaving PricewaterhouseCoopers when KPMG approached him before Christmas. However, he was attracted to the opportunity to specialize in transfer pricing. He had also worked with KPMG in the past and knew people there.

Group treasury companies may be viewed as nothing more than a corporate moneybox or as in-house banks. Careful consideration of the circumstances is required. By Gareth Green, Ernst & Young, London

The German Tax Reorganization Act in force since 1995 permits three types of divisive reorganizations – split-ups, split-offs and drop-downs – without triggering tax, provided two principal conditions are met: any unrealized appreciation (hidden reserves) inherent in the assets transferred must remain subject to German taxation; and the assets transferred – and for split-offs the assets retained as well – must constitute a branch of activity, an interest in a commercial partnership, or a 100% share in a corporation. The latter requirement poses many issues. Until recently, the tax authorities interpreted the key term "branch of activity" in such a way as to severely restrict the options available to taxpayers when structuring divisive reorganizations.

Recent developments in the US courts, the IRS, and the WTO and OECD are looked at in detail

The UK has vetoed plans to introduce legislation on e-commerce taxation in the EU. The revised Swedish proposal would have made non-EU companies selling digitized products to EU consumers liable to value-added tax (VAT) on their sales. This would have levelled the playing field with their EU competitors who are already being charged VAT.

Germany’s Federal Ministry of Finance has changed taxation on the sale of and disregarded a recent court ruling for convertible and exchangeable bonds. By Florian Schultz, Linklaters Oppenhoff & Rädler, Frankfurt

The growth in global e-commerce is giving tax authorities and taxpayers the world over some major issues to contend with. This article looks at the Indian response to the challenge. By Ajay Mehra and Rakesh Jariwal, Arthur Andersen, India