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