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Hartwig Welbers A key condition of Organschaft or tax group is a valid profit pooling agreement between parent and subsidiary. Its effect is that the subsidiary surrenders its entire annual profit to the parent while the parent enters into a corresponding obligation to assume any loss. Company law requires compensation of minority shareholders for their inability to receive a dividend on the surrender of the entire annual profit to the parent.

In 2008, the Irish government established a commission to review the structure, efficiency and appropriateness of the Irish taxation system. The commission published its report on September 7 2009. The commission proposed various reforms relevant to Irish corporate taxpayers.

Paul Tamaki Sabrina Wong The Tax Court of Canada has held that, where a statutory rule does not apply, the residence of trusts should be determined using the test of central management and control (CMAC).

Ian Farmer Technology and collaboration allow sharper focus Greater leverage of technology and collaboration between Australian Government agencies has provided tax administration with a significant leap forward in accessing and analysing information to target risks.

The ratification of the Vienna Convention is an important step in bringing to Brazil the international standards of interpretation of treaties in general and, specifically, of tax treaties, explain Luiz Felipe Ferraz and Julia Nogueira of Demarest e Almeida

The Laerstate case shows that the UK tax authorities are having some success at disputing corporate residence, explain Lee Khvat and James Ross of McDermott Will & Emery's London office

Intellectual property structures prosper in Cyprus Sophie Stylianou For companies active in the development and licensing of intellectual property (IP) rights, efficient ownership structuring is vital. The direction of the relevant licence payment is also important so as to make transactions as tax efficient as possible.

New York was the place to be for another successful evening at International Tax Review's America Tax Awards

Martin Zetter, Ben Blumenfeld, Kirsty Butler and Bhasha Singhal of Ernst & Young's financial services transfer pricing practice examine the economic implications of the recent financial crisis on transfer pricing

Mexico is facing sweeping tax reforms in 2010. Catherine Snowdon speaks to practitioners and government officials to learn more about the plans, which include a higher corporate tax rate, and why they have been introduced now.