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22 Int'l Tax Rev. 1 (2011-2012)

handle is hein.journals/intaxr22 and id is 1 raw text is: www.internationaltaxreview.com I Contents Volume 22: Number 1 8 2011 preview Tax developments to look out for in 2011 Tax commanded the headlines in 2010 as governments sought to enforce rules more strictly in an attempt to get to grips with budget deficits and the issue of the ethics of tax avoidance became mainstream. International Tax Review looks forward and highlights what taxpayers need to be aware of during 2011. 16 Trust cases Canada court shatters trust arrangements Two cases from the Federal Court of Appeal in Canada 2011, but th have opened the door for greater scrutiny of trust arrangements. This new case law, coupled with an emboldened Canada Revenue Agency, will probably mean more pressure on taxpayers that set up these vehicles to avoid income tax. Erin Kelechava looks at the way these cases will affect tax planning, and how they may be illustrative of a broader trend against tax avoidance in Canada. 18 Transfer pricing Hopes rise for stable transfer pricing in 2011 Another year of transfer pricing develop ment brings hope, for taxpayers and their advisers, that processes will be streamlined, guidelines will provide clari ty and policy reform will allow for better interpretation. A new year allows for contemplation about the direction governments and tax authorities should take. Sophie Ashley reports on the expectations for global and regional advances. 21 Tax treaty Canada's treaty with India begins to pay off Elizabeth Bearese investigates the finer details of Canada's tax treaty with India and explains how the treaty has become increasingly important as the two countries seek to develop better investor relations. 23 UAE Taxpayers face challenging future in the UAE The offshore centres of the United Arab Emirates attract companies and investors by low or zero taxation and weak regulatory compli- ance rules, often connected with simple and fast incorporation procedures. However, as Sabine Ebert points out, other countries have enacted legislation, meaning international legal and tax advice is needed and carefully structured set- ups are essential to avoid shortfalls. 26 Deal analysis BP works through solar tax problems BP Solar's sale of a number of PV plants in Italy to a leading insur- ance company gave rse to a complex tax structuring case, which was also affected by a new interpretation by Italy's tax authorities, explains Fedenco Trutalli of NCTM, who advised the seller during the transaction. 28 India India searches for GAAR best practices As India prepares itself to introduce general anti-avoidance rules in April 2012, Mukesh Butani of BMR Advisors (Taxand India) highlights the key issues within the new provisions, compares them to the other jurisdictions, and discovers that India has a long way to go in establishing best practices. 31 Portugal Changes to Portuguese participation exemption Filipe Romio and Antonio Castro Caldas of Uria Men6ndez - Proenga de Carvalho discuss the practical implication of amend- ments to Portugal's participation exemption regime and discover that the changes leave a lot to be desired when compared to its European counterparts. 36 SPEC AL FEATURE: IP Turning tech investments into value repositories Developing transfer pricing policies for IP migration requires a patient, diligent and thorough approach, believe Keith Reams, Mark Nehoray and Emily Dickert of Deloitte. 42 Compound interest Challenges with compound interest in VAT claims Robert Waterson of Dorsey & Whitney explains why recent and ongoing develop- ments inVAT compound interest litigation have raised concerns for both taxpayers and HMRC overVAT claims. 44 Tax disputes A selection of the type of articles you can expect to find in Tax Disputes Week, International Tax Review's newest online-only publication. 50 SPECIAL FEATURE: Intellectual property Tax-effective IP management: IP and corporate charges The second in a series of 10 articles on tax-effective intellectual property (IP) man- agement, Hendrik Fiigemann, Philip de Homont, and Alexander Voegele of NERA Frankfurt present a case study on corporate charges. 52 SPECIAL FEATURE: Tax treaty Cyprus and Russia protocol to encourage investment The signing of a protocol to amend the double taxation treaty between Cyprus and Russia will lead to greater cooperation between the two countries. Effective on January 1 2011, Christodoulos Damianou and Michalis Zambartas of Eurofast Taxand Cyprus explain how information exchange and substance are top of the protocol's agenda. News analysis People International updates Tax relief 4 6 54 68 February 2011 INTERNATIONAL TAX REVIEW' LE

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