Ernst & Young Its Global Dispatch

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