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Nélio Weiss Philippe Jeffrey Two decrees published on October 5 and 18 2010, introduced changes to the tax on financial transactions (IOF). They have increased the rate applicable to inflow currency transactions for investments in the Brazilian financial and capital markets to 4% for operations contracted from October 5 to October 18 2010, and to 6% for operations contracted on or after October 19 2010.

Ian Farmer On October 27, the Australian Commissioner of Taxation's issued the long-awaited Taxation Ruling (TR 2010/7) on how the thin capitalisation provisions interact with the transfer pricing provisions. TR 2010/7 formalises and expands on the views that the Australian Taxation Office (ATO) had put forward in its previous draft ruling, TR 2009/D6.

Robert Lulo According to amendments to the Law on Foreign Investments (Law no 7764, November 2 1993), foreign investments in Albania will be protected by the government, in regard to the problems faced with real estate properties.

France’s thin capitalisation rules are being drastically amended at the end of year in the 2011 Finance Act. Laurent Borey and Antoine Belgrand, of Mayer Brown argue that taxpayers need to pay close attention to these changes or face problems down the line.

With the release of Circular 42/E, the Italian tax administration provided clarification regarding the methods of application of article 113 of the Italian Tax Code. Fulvia Astolfi and Antonella Prencipe of Hogan Lovells explain.

Tax authorities around the world are stepping up their enforcement of transfer pricing rules. It means taxpayers must prepare adequately to address any of their concerns, say Todd Wolosoff and Larry Powell of Deloitte

The competition to provide advice of the highest quality to taxpayers in Asia was evident at the Asia Tax Awards, which were presented in Singapore on November 23 and which were attended by leading tax directors, officials and practitioners from throughout the region.

In early 2010 the OECD released a discussion draft implementation package that provides for a streamlined withholding tax relief process. Paul Radcliffe of Citi looks at the industry responses to the proposals and explains why a consistent international approach to modernising rules in this area is vital.

Canadian multinationals can expect to face more audits in the coming years as the Canada Revenue Agency (CRA) focuses on enforcement activity.

A company’s obligation to its shareholders is to minimise tax and a government’s, to its people, is to close the tax gap. Where does that leave tax planning? Sophie Ashley talks to government officials, taxpayers and advisers to uncover where the confusion lies in a changing environment.