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On April 29 2014 China's Ministry of Finance and State Administration of Taxation jointly issued Circular Caishui [2014] 43 (Circular 43) which provides for the entry into force of the Value Added Tax (VAT) reforms of the telecommunications sector, effective from June 1 2014.

President Obama recently released his annual Budget recommendations for fiscal year 2015.

John Henshall and Achim Roeder explain why it would be unwise to underestimate the impact of business restructuring. The impact extends to the discussion on the revision of chapter VI of the OECD transfer pricing guidelines on intangibles.

Increased globalisation has resulted in significant pressure on US multinationals to take a more global view not only of their operations but also of the manner in which they hold, manage, and develop intangible assets. As a result of these drivers, transferring intangible property (IP) out of the US group to a controlled foreign corporation (CFC) may make sense, explain David Cordova, Gretchen Sierra and Douglas Cowan.

Marco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach.

As energy firms discover and exploit new reserves which require significant amounts of financing, tax authorities have increased their focus on the intra-group financing transactions of such companies. Randy Price, Nadim Rahman and Bill Yohana of Deloitte investigate why the materiality of these transactions may have also increased taxation authority interest in the intra-group financing transactions of energy firms.

Japan will reduce its corporate tax rate by five percentage points to 35% from next April, in an effort to boost the country’s ailing economy.

Since June 2008, when a broadened definition of low-tax jurisdictions (tax havens) was introduced by the authorities, taxpayers have been eagerly awaiting the enactment of an updated black list of tax haven jurisdictions for tax and transfer pricing purposes. The latest version of the black list was issued in August 2002.

A country's tax policy is reflected in its domestic tax legislation as well as its tax treaty positions.