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John Whiting John Whiting has been appointed to the new role of tax policy director at the Chartered Institute of Taxation (CIOT ) in London. The practitioner will take early retirement in June from the London office of PricewaterhouseCoopers, where he is a partner. Whiting's brief is to lead the development and presentation of the CIOT's views on tax policy matters, making sure these are developed consistently within all the CIOT's technical work.

John Belsey John Belsey has moved to Dubai to head Deloitte's international tax services and M&A tax practice in the Middle East. He was formerly an M&A tax partner in London and was the client relationship partner for some of the firm's biggest global clients, as well as leader of the firm's services to the UK government and public sector.

Phani Tillirou Cyprus is established as an international business and financial centre and has the lowest corporation tax rate in the EU of 10%. A significant number of double tax treaties have been concluded, the usage of which, has greatly prevented double taxation resulting in a reduction of the tax payable. The existence of such treaties combined with the low corporate income tax in Cyprus offer tremendous possibilities for tax planning through Cyprus.

Sean Foley On Christmas Eve, in the closing days of the Bush administration, the US Treasury department and the IRS released final and temporary regulations addressing the treatment of contract manufacturing arrangements under the US anti-deferral regime known as Subpart F. The final and temporary regulations are effective for tax years of controlled foreign corporations (CFCs) beginning after June 30 2009.

Edward Tanenbaum The qualified intermediary (QI) system is a set of rules governing the "know your customer" information gathering process, as well as withholding and reporting obligations with respect to payments made by US withholding agents to foreign financial institutions holding custodial accounts on behalf of their beneficial owner customers. As a general rule, in exchange for not disclosing the identity of foreign beneficial owners to the withholding agents or to the IRS, an elaborate systems and procedures check is required to be performed by the foreign financial institution's external auditor who is then required to furnish a report to the IRS with its findings.

Jane Dodd On January 26 2009, HM Revenue & Customs (HMRC) announced certain exclusions with respect to the worldwide debt cap including an exclusion for the UK-REIT regime. The worldwide debt cap operates such that UK interest deductions claimed by large groups will be capped where the UK has more debt than the external debt of the worldwide group.

Carl Pihlgren Sara Bolmstrand On November 24 2008 the Swedish tax agency submitted a proposal to the Swedish government relating to partnerships and the application of the Swedish participation exemption rules. The proposal suggests among other things that the disposal of an interest in a partnership by a Swedish corporate taxpayer could benefit from the application of the Swedish participation exemption. Also, the proposal suggests that a partnership can benefit from the participation exemption rules even if it is not a taxable entity itself.

Manuel Ángel Bouzas In October the Spanish government approved the long-awaited regulations for the development of the new Spanish transfer pricing rules.

Nathalie Urban Daniel Gremaud The Swiss federal government, the Federal Council, recently announced a range of corporate tax reforms designed to increase Switzerland's attractiveness and prospects for growth as a business location. A draft consultation paper on corporate tax reforms will now be prepared by the federal department of finance.

Marius Ionescu Lucian Barbu The end of 2008 and the beginning of 2009 brought significant changes to the Romanian tax legislation, mainly aimed at counterbalancing the downgrade of the Romanian economy, especially as regards the capital market, banking and real estate sector.