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
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.

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
International updates
Tax relief


February 2011



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