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As company profits fall and direct tax receipts plummet, tax authorities will start looking to indirect taxes to generate revenue. Joanna Faith finds out what tax departments should be doing to prepare for this shift in focus.

Rolf Wüthrich of VISCHER explains that new legislation has increased Switzerland's appeal as a location for this kind of financial instrument

By Ralph Cunningham

Pedro Fernández The Bill on REITs was finally submitted to Congress and is under discussion. It is very different from the draft.

Edward Tanenbaum On December 19 2008, the Internal Revenue Service (IRS) issued proposed regulations that address the application of the conduit financing arrangement rules of Treasury regulation § 1.881-3 to structures involving disregarded entities.

Mika Persson Erik Hultman According to current Swedish tax rules, so-called prohibited loans, i.e. loans given in violation of the Companies Act, are taxable for Swedish borrowers (including situations where loans are raised indirectly via Swedish partnerships). Loans from foreign entities are not covered by the rules and it has been possible for individuals to own closely-held companies via foreign entities, and to borrow funds from these entities instead of receiving highly taxed dividend distributions.

Henry An David Jin-Young Lee Corporate Tax Rates: The two-tier corporate income tax rate structure of 11% of taxable income up to KRW 200 million (approximately $144,259) and 25% of taxable income in excess of KRW 200 million will be reduced to 11% and 22%, respectively, in 2009 and further reduced to 10% and 20%, respectively from 2010.

Rajendra Nayak Ganesh Pai The Delhi Income Tax Appellate Tribunal (ITAT) in the case of Rolls Royce (2009-TIOL-103-ITAT-DEL) recently examined certain issues relating to attribution of profits to a permanent establishment (PE). Rolls Royce is a company incorporated in the UK and is engaged in the business of supplying aero engines to Indian customers. Under an agreement, its UK subsidiary, Rolls Royce India Limited (RRIL), through its offices in India, provided marketing, business development and other support services to the taxpayer on a cost-plus basis. In an earlier order of the ITAT relating to the taxpayer, it was held that RRIL was a dependent agent of the taxpayer and the taxpayer through RRIL, had a dependent agent PE in India under article 5(4) of the double taxation avoidance agreement between India and UK.

Janne Omsland On January 26 2009, the Norwegian government proposed a loss carryback for losses incurred in 2008 and 2009. The measure is part of a package to address the economic crisis. The proposal was passed by the Norwegian Parliament on February 19 2009 and approved by the King in Council on February 27 2009.

Diane Hay, former deputy director, CT & VAT and head of the Transfer Pricing Group at HMRC tells Catherine Snowdon about some of the main difficulties she tackled while at the revenue authority and part of working party 6, offers taxpayers an insight into how transfer pricing cases are selected in the UK and talks about the future of transfer pricing.