Ernst & Young ITS Global Dispatch

European Commission Action Plan to strengthen fight against tax fraud and tax evasion -- Protocol to Belgium-UK treaty entered into force -- French Parliament approves Finance Bill 2013 -- Ireland's 2013 Budget published --Latvia introduces new participation exemption, withholding tax regime -- Spanish Parliament enacts law affecting Spanish resident entities and PEs --UK releases guidance on administering US-UK FATCA agreement -- Argentina to begin new "Early Declaration for Payments Abroad" -- Mexican Congress approves tax amnesty --US-Spain sign comprehensive tax protocol

Germany's Annual Tax Act to implement Authorized OECD Approach for PEs -- New Finnish Bill would restrict interest deductibility -- Luxembourg Government presents amended 2013 Budget proposals -- Tightened Swedish interest limitation rules and lowered CIT rate approved by Parliament -- New start date for Australia's proposed amendments to GAAR - Hong Kong signs tax treaty with Canada -- Argentina ratifies Multilateral Convention on Mutual Administrative Assistance in Tax Matters -- US issues second Model FATCA Intergovernmental Agreement -- US FATCA negotiations moving forward

UN releases draft Transfer Pricing Practical Manual for Developing Countries -- OECD issues revised draft changes to Commentary on Article 5 (PE) and beneficial ownership -- Australia announces tax changes in Mid-Year Economic and Fiscal Outlook -- Colombian tax bill introduces new consumption tax, income tax supplement, anti-abuse rules and transfer pricing changes -- Malaysia issues 2013 budget proposals -- Portugal's State Budget Law for 2013 submitted to parliament; includes new interest deduction limitation rules

India publishes rules for implementing Advance Pricing Agreements -- India's Advance Ruling Authority upholds nontaxable treatment of share buyback by Mauritius company -- Japan's NTA publishes voluntary transfer pricing information checklist -- Taiwan clarifies character of payment to foreign entity for online database services to Taiwanese customers -- Brazil converts Provisional Measure into Federal Law amending transfer pricing rules -- Panama introduces changes to transfer pricing regulations -- US, UK sign bilateral FATCA agreement -- Russian issues guidance on transfer pricing documentation -- Sweden proposes reduction in corporate tax rate

Canada releases legislative proposals to implement 2012 federal budget -- Australia enacts major transfer pricing law changes -- China to expand VAT pilot program to 8 more locations, including Beijing -- India issues tax policy announcements to address business concerns -- Japanese Diet passes consumption tax reform bill -- Taiwan to reinstate capital gains tax on Taiwan securities trading -- Denmark considers bill whereby all loans from companies to shareholders considered non-repayable withdrawals, i.e., dividends, contributions or salary income -- France's Second Amended Finance Bill for 2012 final -- Italian Supreme Court rules on PE issue related to Italian company acting as commissionaire for Dutch principal -- Israel considers temporary benefit on repatriation of funds

China further clarifies beneficial ownership for tax treaty purposes -- India releases draft guidelines for new anti-avoidance regulations (GAAR) -- Vietnam approves National Action Plan on transfer pricing for 2012-2015 -- Polish court challenges procurement support transactions with related entity -- Spain introduces new tax measures to reduce public deficit -- Argentina withdraws from tax treaty with Chile and Spain -- Brazil introduces reporting requirement for cross-border service and intangible transactions -- US releases FATCA Model Intergovernmental Agreement

Dutch Finance Ministry releases tax budget proposals for FY 2013 -- Danish Parliament adopts major new rules on company taxation -- Italy issues Circular Letter on settling international tax disputes, MAP process -- Spain, US announce agreement on new tax protocol -- Sweden present revised proposal tightening interest expense deduction on intra-group loans -- OECD publishes proposals for revised guidance on transfer pricing of intangibles -- Korea issues English language treaty claim forms -- Malaysia releases transfer pricing, APA rules -- Singapore clarifies rules on nontaxable gains on equity investment disposal -- US Treasury issues FATCA statements with Japan and Switzerland -- US Supreme Court rules on landmark health care law

India's Finance Bill 2012 enacted with major international tax amendments -- Denmark considers significant changes to company taxation -- Germany, Netherlands sign new tax treaty -- Spanish Supreme Court narrows entitlement to EU Parent-Subsidiary Directive -- Argentina releases proposed tax reform -- Brazilian court rules payments for services lacking know-how transfer not subject to withholding -- El Salvador issues transfer pricing guidelines

Canadian Budget 2012 includes international tax proposals -- New Argentine FX rules have tax consequences -- Brazil modifies transfer pricing rules -- Finland circulates draft interest expense restriction proposal -- Spain introduces changes to international tax framework -- Sweden proposes tightening interest limitation rules -- Delhi High Court rules on transfer pricing aspects of royalty payment to associated enterprise -- Japan's 2012 tax reform adopted -- Taiwan plans to resume capital gains tax on transfer or securities

UK releases anticipated Budget 2012, corporate rate reductions -- Indian Union Budget 2012-13 addresses Vodafone, other major changes -- Australia to amend General Anti-avoidance Rule -- Australia releases revised draft legislation on proposed Investment Management Regime -- Hong Kong announces new group-recharge deduction position -- Japan's NTA releases transfer pricing guidance for examiners -- European Commission announces new consultation on double "non-taxation" -- Italy amends exit taxation; opportunity for MNCs -- Italy issues draft regulations on notional interest deduction regime -- Argentina adopts new "Early Declaration System for Services" -- Colombian Constitutional Court rules minimum ownership for indirect tax credits for taxes on earnings from foreign shares unconstitutional

Tax Court of Canada issues landmark decision on "beneficial ownership" -- Argentina unilaterally terminates tax treaty with Switzerland -- Argentine tax authorities implement new "Early Import Declaration" mechanism -- Mexico reorganizes Certified Company Program; tax consequences for IMMEX companies -- Mexican tax refund opportunity for international airlines operating in Mexico --Belgium-Democratic Republic of Congo tax convention in force; Congo's first tax treaty -- Danish exposure draft includes important changes to company taxation -- Irish government publishes Finance Bill 2012 -- Indian tribunal rules on characterization of entities' activities for transfer pricing purposes -- Indonesian regulation affects MAP and APAs

Indian Supreme Court rules in long-awaited Vodafone case -- New Japan-Netherlands tax treaty effective -- Japan-Swiss tax protocol effective -- Korea revises tax laws -- Irish Budget reaffirms 12.5% corporate tax rate -- Israel raises tax rates, other changes -- Italy enacts austerity measures, positive tax changes -- Italy clarifies unlimited carryforward; applies to losses from 2006 -- New tax regime applies for Portugal's Madeira International Business Center -- Spain increases tax rates for 2012 and 2013 -- Brazil adopts adjustment mechanism on transfer prices of export transactions

New Switzerland-Netherlands tax treaty effective January 2012 -- Norwegian National Budget for 2012 contains major tax proposals -- Portuguese 2012 Budget Act proposals will impact cross-border transactions and foreign investment -- Angola proposes transfer pricing documentation rules -- New UK –South Africa tax protocol enters into force -- China announces new Shanghai VAT pilot to replace business tax -- Changes to Japan’s transfer pricing legislation effective -- Malaysia’s 2012 budget contains corporate tax incentives -- Colombia eliminates restrictions on foreign debt; intercompany loans now possible

Australian Treasury releases draft legislation for extending Petroleum Resource Rent Tax -- Australia releases shipping industry tax reform package; zero rate for Australian ship operators -- Hong Kong Inland Revenue considers R&D must be carried on directly by taxpayer for deduction -- Hungary submits 2012 tax bill to Parliament -- Draft Russia-Luxembourg protocol details available -- Canadian panel issues final R&D recommendations -- Mexico's IETU tax credit for maquiladoras extended

Dutch Finance Ministry releases FY 2012 budget proposals -- French National Assembly and Senate approve Second 2011 Amended Finance bill -- Israel excludes certain related party financing from transfer pricing rules -- China requiring foreign nationals to participate in social security system -- Indian transfer pricing cases address "associated enterprises" and cost contribution arrangements -- Taiwan defines amortizable "business rights" -- Brazil again amends Financial Transactions Tax (IOF) -- Colombia - Switzerland treaty to take effect

Canadian MAP report reflects greater transfer pricing audit activity -- Mexican court issues first pro-taxpayer transfer pricing ruling -- New VAT rules for Mexican Maquiladoras -- France announces budget, tax measures to reduce deficit -- Italy issues guidance on outbound dividend withholding taxes -- Italy amends corporate income tax surcharge for energy industry -- Spanish Tax Court denies participation exemption benefits to Brazilian interest on net equity payments (JsCP) -- Spanish Decree contains temporary corporate tax, VAT measures -- Turkey announces first APA -- Turkey, Malta sign first-ever tax treaty -- Indian transfer pricing audits indicate increased focus -- Malaysia gathering information on transfer pricing -- Vietnam intensifies focus on transfer pricing

Dual challenges to Dutch fiscal regime may be of importance to multinational groups -- Recent Indian transfer pricing rulings of note -- Japan enacts certain tax reform measures -- Thailand enacts tax incentives for international procurement centers -- Colombia introduces 1% self-withholding on exportation of hydrocarbons and mining products -- Dominican Republic issues transfer pricing regulations

OECD proposes clarifications to term "beneficial owner" in Model Treaty -- Norwegian court puts commissionaire structures at risk -- Australian government issues 2011-12 federal budget -- China focusing on financial services transfer pricing -- Hong Kong court issues favorable offshore profit decision -- Japan releases circular on corporate tax treatment of damages from March disaster; procedures to finalize 2011 tax reform on hold -- Brazilian government issues thin capitalization guidance -- Tax Court of Canada renders important transfer pricing decision

Dutch government publishes important tax policy paper -- Ireland-Singapore treaty moves forward -- Israeli tax exemption on Makams and government bonds to be abolished -- Draft Italian decree on "European attraction tax" released -- Luxembourg issues guidance on intra-group financing -- Norway presents White Paper on tax-free cross-border reorganizations -- Turkish Commercial Code published in Official Gazette -- Brazil removes Luxembourg holding companies from privileged tax regime list -- Brazil again increases tax on financial transactions -- EY learns details on PRC plans for transfer pricing adjustments

European Commission releases proposed directive on common consolidated corporate tax base (CCCTB) -- Dutch government publishes Decree on attribution of profits to permanent establishments -- OECD scoping paper released on transfer pricing for intangible property -- Spain, Germany sign new tax treaty -- UK 2011 Budget released -- HK denies deduction for plant and machinery used under import processing arrangement -- India releases Union Budget for 2011-12 -- Japanese transfer pricing assessments rising, APA tracking increases -- Japan’s proposed 2011 tax reform addresses transfer pricing -- Singapore's 2011 Budget delivered -- Comprehensive Mexican tax reform bill submitted

Ireland introduces new transfer pricing rules -- Finland releases final report on tax proposals -- New Belgium-Chile tax treaty and protocol effective -- France-Taiwan income tax arrangement in force -- EU Commission: Germany's insolvency restructuring exception in ownership change rules unlawful state aid -- New Hungary-Taiwan tax treaty in force -- Polish treaties with Finland and Norway in force; interest exemption unavailable -- OECD releases scoping paper on intangibles -- PRC imposes stricter enforcement of foreign representative offices -- Indonesia releases APA regulations -- Taiwan's first thin cap rules effective -- Mexico expands tax treaty network in Latin America

Japan releases outline of 2011 tax reform -- China issues first report on APAs -- Austria releases transfer pricing guidelines -- French Parliament enacts Finance Bill for 2011, Amended Finance Bill for 2010 -- New Luxembourg regime for highly-skilled expats -- Spain amends rules to apply EU Parent Subsidiary Directive -- EU Commission requires Spain to abolish scheme favoring acquisitions in non-EU countries -- Egypt issues transfer pricing guidelines -- Israel approves new capital investment law -- Brazilian tax reductions to stimulate private lending for infrastructure -- Brazilian financial transactions tax reduced -- Mexico enacts important changes to IMMEX regime (maquiladoras)

Italy releases guidance on transfer pricing documentation regime -- Belgium issues circular on reporting requirements for payments to tax havens -- German guidance on real estate transfer tax reorganization rules released -- Ireland's 2011 Budget confirms 12.5% corporate rate -- Spain enacts major changes to capital duty legislation -- Switzerland adopts capital contribution principle: urgent action recommended -- Australia releases tax determinations on private equity funds -- Australian government announces plans to prevent ATO from assessing foreign managed funds -- Hong Kong signs treaties with Japan and France -- US-Malta treaty in force -- US, Canadian arbitration guidance released

Austrian tax proposals contain significant international tax changes -- Proposed French Finance bill 2011 may expand scope of thin capitalization rules -- Irish government confirms 12.5% corporate tax rate -- Portugal's Draft Budget law 2011 tightens withholding exemption, domestic participation exemption -- ECJ rules Spanish real estate transfer tax compatible with EU Capital Duty Directive -- Switzerland signs new tax protocol with Germany -- Switzerland, Canada sign protocol with withholding reductions -- More on India's Vodafone case -- Colombian tax reform bill to eliminate super deduction for investments in fixed assets -- Malaysia 2011 budget announced -- Panama and Netherlands sign tax treaty -- US, New Zealand tax protocol enters into force

Hungary proposes flat 10% corporate tax rate -- Israeli draft budget 2011-12 would revamp tax incentives regime in 2011 -- Italian guidance released on new CFC rules, black-list dividends -- New Italian instructions for transfer pricing documentation requirements -- Liechtenstein approves major tax reform -- Russian officials confirm new transfer pricing rules to be signed into law this year -- Update on Turkey's withholding tax changes -- Brazil twice increases Tax on Financial Transactions for foreign investments in fixed income -- Mexican budget leaves tax rates unchanged -- Indian discussion paper looks at foreign investment through LLPs -- Recent transfer pricing developments in Vietnam

Indian court rules in Vodaphone cross-border M&A case -- Indonesia issues new treaty rules -- Japan-Netherlands sign new treaty -- Singapore adopts lower withholding for routine support services -- Update on Taiwan's preferential withholding rate -- OECD addresses transfer pricing implications of business restructuring -- New Swiss guidelines on internal treaty-abuse rules -- South Africa enacts controversial transfer pricing rules -- Chile temporarily increases corporate tax rate

Italy enacts Home State Taxation for new businesses -- Austrian proposal would limit interest expense deduction for stock acquisitions -- Ireland narrows scope of royalty withholding -- Israel takes aggressive stand on business conversions of tech companies -- ECJ rules Spain's tax treatment of dividends to non-Spanish EU resident companies illegal; refund options -- Brazil's new transfer pricing rules expire -- Mexico alleviates tax reporting burden for taxpayers -- Panama announces complementary rules for tax treaties -- US enacts major international tax changes -- India releases revised discussion paper on proposed tax reform -- Taiwan issues mutual tax exemption regulations on cross-strait sea and air exemption agreement with Mainland China

New UK government releases emergency budget; outlines roadmap for corporate tax reform -- European Commission requests Belgium, Denmark, and the Netherlands amend exit tax rules -- Ireland's transfer pricing rules become law -- Italy adopts transfer pricing documentation measure -- South Africa proposes transfer pricing, thin capitalization changes -- More information on Japanese transfer pricing documentation requirements -- Taiwan further reduces corporate tax rate -- Vietnam issues new transfer pricing circular -- Argentine government considers new regime to promote local shared services centers for service rendered abroad -- Canadian government releases policy on requesting access to accountants' and auditors' working papers -- Canada signs TIEA with Bermuda and St. Kitts and Nevis

Canada releases details of proposed reporting requirements for tax-avoidance transactions -- Cyprus adopts new shipping tax legislation -- German update on new tax rules for transfer of business functions -- Italian Central Revenue releases unilateral APA statistics -- Swedish tax agency floats proposed CFC changes -- UK unveils new treaty relief process -- New Australian Resource Super Profits Tax raises concerns -- Thailand issues bilateral APA guidelines -- Canadian ruling sanctions cash repatriation strategy from Canada -- US Customs approves use of TP study to support related-party pricing

China Circular 19 increases deemed profits for nonresident service providers -- China consolidates tax rules for representative offices -- New China-Barbados protocol in force -- French court rules French commissionaire is not a PE -- European Commission requests Germany amend anti-treaty, anti-directive abuse rules aimed at withholding tax relief -- Italy introduces new reporting rules for transactions with black-listed countries -- Russia approves new draft model income tax treaty -- UK Budget released -- Hong Kong, Netherlands sign comprehensive tax treaty -- Update on India's draft direct tax code -- India-Mauritius tax treaty developments -- Japan's 2010 tax reform effective 1 April or 1 October 2010 -- Taiwan-Israel tax treaty and protocol in force -- Canadian court rules US LLC is a treaty resident -- US Congress enacts new reporting and withholding rules for domestic, foreign financial institutions

Russian draft transfer pricing law moves forward -- Spain amends nonresident income tax law for non-Spanish EU residents lacking PE -- Sweden revising cross-border "group deduction" proposal -- Indian finds no CGT on intra-group share transfer lacking consideration -- Singapore budget introduces new tax incentives -- Taiwan again revises surtax credit computation applied against dividend withholding -- Canadian budget 2011 addresses international taxation -- El Salvador introduces important transfer pricing changes

Irish Finance Bill 2010 includes enhancement's to holding company rules, announces introduction of transfer pricing regulations -- Germany proposes arm's length individual asset approach for business transfers -- Norwegian commissionaires may pose PE risk -- Spain expands ETVE tax benefits -- Swiss court rules FX differences do not qualify as income or expenses -- UK publishes discussion draft on CFC proposals -- Singapore introduces new tax regime for corporate amalgamations -- Taiwan issues regulations governing tax treaties -- Mexico proposes controversial changes to IMMEX, or Maquiladora Decree -- US MNCs with Venezuelan operations must adopt DASTM -- US signs treaties with Hungary and Chile

Dutch shelve proposals reforming taxation of interest income and expenses -- French parliament enacts Finance Bill 2010, amended Finance Bill 2009 -- New France-United Kingdom treaty and protocol enters into force -- Hungarian Parliament approves new corporate tax law; ETR on interest income earned abroad 4.75% from 1 January 2010 -- Russian Finance Ministry publishes new draft transfer pricing law -- Swedish tax rules effective 1 January 2010 -- UK presents annual pre-budget report -- China issues guidance on term 'beneficial owner' under tax treaties -- Hong Kong issues transfer pricing guidelines -- Indian tax authorities address tax treatment of installation permanent establishments -- India releases discussion paper on future Goods and Services Tax -- Indonesian regulations to combat tax treaty abuse -- Japanese government outlines 2010 tax reform proposal -- Japan and Netherlands announce terms of new tax treaty -- Brazil introduces significant tax changes including thin capitalization rules