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Marta Szafarowska All Polish companies using group financing have to prepare for a completely new thin capitalisation rules from January 2015 to avoid significant adverse effects on their tax position. This refers in particular to all those taxpayers who, to avoid such negative effects, use financing granted by their grandparent companies. Basically, existing thin capitalisation rules apply only to loans granted by direct shareholders, provided that such loans exceed the equivalent of three times the value of the company's share capital. Consequently, most of the companies requiring group financing (for example, leasing and CFM companies) have been financed by their grandparent companies. The new provisions envisage not only covering the financing from grandparent companies with thin capitalisation rules, but also the new debt:equity ratio. The thin capitalisation rules will apply if the amount of debt towards related parties exceeds the amount of the company's equity (instead of three times the company's share capital). A very limited netting of debt has also been envisaged – generally, to apply the above rules the loans granted by related parties will be reduced by the loans granted by the taxpayer but only to those related parties. From the perspective of CFM or leasing companies such netting is completely insufficient.

Donald Vella

In diaper need of reform: Tax Relief proposes new penalty system Tax Relief has heard of people not declaring things on their tax return; of course, there have been various initiatives around the world aimed at cracking down on tax evasion. But this story is more about invention than evasion. Joanna Hawkins-Mahaffey, a resident of Peterborough, Ontario in Canada, has been fined more than $142,000 after pleading guilty to five counts of making false or deceptive statements and wilfully claiming false tax credits. On top of the fine, she has been sentenced to 90 days in jail.

Still playing the wild grover: Often seen on the Hill, Norquist’s festival visit shows he is not yet (Gr)over it

Reto Savoia

"The impact so far is limited, but we keep a close eye as technology is rapidly improving. To remain in control, technology is ultimately required and, at the same time, one can act more pro-actively once technology is in place."

Jayesh Sanghvi of EY looks at some of the key international tax developments that are having an impact on India.

Maik Heggmair, Kai Schwinger and Nicolas Boehlke of WTS recount their experiences with Chinese tax law and related party transactions between Germany and China from a German perspective.

An ability to evolve and innovate in line with international regulatory developments and investor demand is key to the success of the Irish financial services industry. Martin Phelan and Niamh Keogh of William Fry Tax Advisors – Taxand highlight some recent tax changes and trends in their financial services practice.

Sumeet Khurana and S. Sriram of Lakshmikumaran & Sridharan look at marketing intangibles in light of the Maruti Suzuki case and contentious tax issues surrounding companies increasingly using international brands to market their products effectively.