Strategizing International Tax Best Practices – by Keith Brockman

Posts tagged ‘best practices’

Vietnam: Risk based audits

KPMG’s Transfer Pricing Alert highlights current transfer pricing audits in Vietnam based on risk assessments, including key observations and insights.

https://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/taxnewsflash/Documents/tp-vietnam-dec18-2013.pdf

Following the Action Plan on Transfer Pricing Management (the Action Plan) announced by the Ministry of Finance under Decision 1250/QD-BTC dated and effective 21 May 2012, the General Department of Taxation (GDT) has rolled out transfer pricing audits across a number of provinces in the context of challenging 2013 tax revenue collection.

Key observations include the preference of transfer pricing methods, secret comparables, irrelevance of commercial/economic factors and arbitrary transfer pricing adjustments.

Audits in Vietnam and similar markets should be monitored closely, noting appeal and arbitration opportunities that may mitigate double taxation.  Refer to my prior post of 2 December 2013 summarizing Vietnam’s proposed anti-treaty shopping rules to deny tax treaty benefits.  

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Transfer Pricing

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R&D/Patent, Innovation Box global summary

PwC Global R&D Incentives Group has published a valuable global summary of R&D incentives, including the Innovation and Patent Box.

Click to access pwc-global-r-and-d-incentives-brochure-may-2013.pdf

The summary provides the status of the R&D Credit, R&D Super Deduction, Patent and Innovation box for the following countries:

  • Australia
  • Austria
  • Belgium
  • Brazil
  • Canada
  • China
  • Czech Republic
  • Denmark
  • France
  • Hungary
  • India
  • Ireland
  • Italy
  • Japan
  • Korea
  • Liechtenstein
  • Lithuania
  • Luxembourg
  • Netherlands
  • Poland
  • Portugal
  • Romania
  • Russia
  • Singapore
  • Slovak Republic
  • South Africa
  • Spain
  • Switzerland
  • Turkey
  • United Kingdom
  • United States

This valuable summary provides an up-to-date status of the R&D, Patent/Innovation Box to develop Best Practices in pursuing these valuable opportunities.

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Tax Risk Management

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Legal Entity governance: Best Practice ideas

Maintaining an up-to-date legal entity organization process / document is an important requirement for accurate and timely tax compliance and planning.  Best Practice ideas for consideration include the following:

Governance sign-off process for all changes of a legal entity, including:

  • Stated capital
  • Share premium (Additional paid-in capital)
  • Authorized capital
  • Officers / Directors
  • Tax elections re: tax characterization
  • Change in name or form of entity
  • Trade names / DBA
  • Restructurings / Mergers / Liquidations
  • Articles of Incorporation or Association

Documentation backup supporting all changes during the life of a legal entity, including formation and dissolution

Assigned Legal Entity champion in the organization

Governance process re: authorized users (view/print/edit)

List of authorized users

Guidelines re: providing legal entity data to third parties, including audit requests

Providing updates with distribution on a real-time (electronic) basis

Master Legal Entity Chart, archiving prior versions as permanent files

Permanent file retention of relevant supporting documentation

Listing of nominee shareholders

Legal and tax characterization, if different

Developing legal entity approval and sign-off in a business recommendation, rather than a separate subsequent process

Most organizations have a process to govern legal entity changes and provide contemporaneous information, although all processes merit a creative review to gain additional efficiencies and Best Practices.

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Tax Risk Management

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Nigeria: New TP Division & Disclosure forms

In concert with the global emphasis on transfer pricing, Nigeria’s Federal Inland Revenue Service (FIRS) has issued new transfer pricing  (TP) forms to be filed with the annual corporate income tax returns for 2013.  Additionally, a new Transfer Pricing Division has been implemented following Best Practices by other tax administrations.

A Transfer Pricing Declaration form and Transfer Pricing Disclosure form are released to implement the TP regulations issued in 2012. The Transfer Pricing Declaration form includes information on the company’s directors and parent company, whereas the Transfer Pricing Disclosure form requests information about the company’s performance in relation to the group, in addition to disclosure of zero consideration goods, services, or intercompany loans.

The new disclosures highlight the trend for increased disclosures, for which there should be Best Practices implemented to ensure timely compliance and global consistency of tax reporting positions.

A KPMG summary is included as an insightful reference.

http://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/taxnewsflash/Pages/nigeria-new-transfer-pricing-forms-dedicated-tax-office.aspx

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Transfer Pricing

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UK transparency initiatives announced

The Prime Minister announced that ownership details of UK companies will be made publicly accessible.

This announcement was preceded by a Discussion Paper in July 2013 outlining various proposals of the initiative, including the statement in paragraph 11: “The names of legal owners appear on an individual company’s share register, which is publicly available.  But if we want to know who really owns and controls a company, we must identify its beneficial owners too.  The beneficial owners are the individuals that ultimately own or control the company – either because they hold an interest in more than 25% of the company’s shares or voting rights; or because they control the management of the company in some other way.”

Links to the announcement, Discussion Paper, and executive summary of the Discussion Paper are attached for reference.

https://www.gov.uk/government/news/public-register-to-boost-company-transparency

Click to access bis-13-959es-transparency-and-trust-enhancing-the-transparency-of-uk-company-ownership-and-increaing-trust-in-uk-business-executive-summary.pdf

Click to access bis-13-959-transparency-and-trust-enhancing-the-transparency-of-uk-company-ownership-and-increaing-trust-in-uk-business.pdf

This initiative is likely to be followed closely by other countries, and details requiring UK disclosure should be reviewed early to adopt Best Practices and address questions arising in the UK and around the world from this public disclosure announcement.  

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Tax Risk Management

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Withholding taxes: Cash efficiencies

Withholding tax rates are increasing in many developing countries, creating additional timing and/or permanent cash inefficiencies.  To the extent withholding tax payments, receipts and documentation are viewed from a Best Practice process perspective, immediate cash savings may be realized.  The following points may be considered in this process:

  • How are payments attracting withholding taxes identified?
  • Identify internal/external responsibility for tracking changes in withholding tax rates and communication to the business payor.
  • Are higher payments being made due to contemporaneous documentation (i.e., certificates of residence) not received timely?
  • What integration is in place for Tax and/or Treasury to manage the withholding tax process?
  • For shared service centers, how are changes in withholding rates communicated for timely implementation?
  • Has an internal and/or external review of withholding taxes been performed in the last year?
  • How are withholding taxes considered for new intercompany loans?
  • Who reviews withholding tax considerations for legal entities in new jurisdictions?
  • For taxes that are not ultimately creditable, is there a process to identify and quantify such payments?
  • Is there a review process for proper characterization of “withholding” taxes that may or may not be creditable?
  • Is there specific responsibility within the business to ensure withholding taxes are properly characterized and paid timely?
  • Should a withholding tax flow chart be used for internal governance and global consistency in methodology?
  • Is there a governance process for collection of receipts when withholding taxes are paid?
  • Identify a process for physical/electronic receipt retention to ensure timely and accurate documentation is maintained for audits.
  • Are different payment flows in place for similar services where withholding taxes apply?
  • Is there a variance analysis performed on a recurring basis to identify significant changes?
  • Are internal governance principles established for withholding taxes?
  • Is the business aware of the importance for efficient mechanisms re: withholding taxes?

Withholding, and similar, taxes are being legislated by many countries, especially in developing markets.  Accordingly, Best Practice processes should be in place to maximize cash efficiencies.

 

 

 

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Tax Risk Management

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Corruption assessment: a component of Global (Tax) Risk Framework

The Eight Millennium Development Goals (MDGs) ...

The Eight Millennium Development Goals (MDGs) of UN. Target date: 2015 http://www.un.org/millenniumgoals/ (Photo credit: Wikipedia)

Today’s tax environment of increased transparency highlights the need to integrate an assessment of corruption into the Global Risk Assessment, including the Tax Risk Framework.  Proper governance includes monitoring perceptions, and actual cases, of corruption globally.  Brief summaries, with links, have been provided for Transparency International and the Global Portal on Anti-Corruption for Development, with additional references and recent articles, for reference.  The Corruption Perceptions Index by Transparency International is included in the first link.

Today the Transparency International movement includes more than 100 independent national chapters and partners around the world, which take action in support of our mission “to stop corruption and promote transparency, accountability and integrity at all levels and across all sectors of society”.

Transparency International calls on the United Nations to adopt a governance goal and governance targets for its post 2015 development priorities

http://www.transparency.org/news/pressrelease/transparency_international_calls_on_the_un_to_make_governance_a_priority_fo

The Global Portal on Anti-Corruption for Development is a one-stop-shop for information and knowledge specialized on anti-corruption for sustainable development. It aims to support the work of development/governance practitioners, anti-corruption bodies, researchers, civil society organizations and the donor community by facilitating easy access to information, cutting-edge knowledge and practical tools on anti-corruption at the global, regional and country level.

The Anti-Corruption for Development web portal is a unique and pioneering UN web platform that provides open access to information and knowledge related to the latest efforts to address corruption prevention against today’s development challenges: human rights, gender equality and empowerment, climate change and natural resource management, achievement of the Millennium Development Goals (MDGs) and Post-2015 Development Agenda, illicit financial flows and transitional contexts, among others.

http://www.anti-corruption.org/index.php/en/about

The Conference of Nigerian Political Parties (CNPP) has asked the Coordinating Minister for the Economy and Minister of Finance, Dr. Ngozi Okonjo-Iweala, to resign forthwith for misleading President Goodluck Jonathan on the damaging level of corruption in the country.

CNPP’s demand came as an aftermath of President Jonathan’s remarks in which he referred to a World Bank report from the minister placing corruption as third in the ranking of problems confronting the country.

http://allafrica.com/stories/201310010283.html

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Industry’s leading third party management software provider advises oil and gas companies to fundamentally re-think supply chain compliance.

With the realization that corruption is undermining development and the achievement of the Millennium Development Goals (MDGs), experts are lobbying the UN to adopt goals and targets on good governance and transparency in the post-2015 development agenda.

A high-level anti-corruption panel, co-chaired by UNDP, Transparency International and UNODC, gathered at the UN in New York in late September to highlight the impact of corruption on development and find ways to ensure that anti-corruption is part of the new global development agenda.

Is internal corruption slowing progress in developing countries?

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OECD / UN, Tax Risk Management

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BIAC Tax Principles/Best Practices/comments re: OECD TP risk assessment

Three new publications have been issued by the Business and Industry Advisory Committee (BIAC) to the OECD.  The publications encompass Best Practices and Tax Principles for Multinational Enterprises (MNEs), as well as comments on the OECD Draft Handbook on Transfer Pricing Risk Assessment.  These reports are worthy to note in an effort to better understand the continuing trend of transfer pricing scrutiny.

http://www.biac.org/policygrp/stmts-tax.htm

BIAC Statement of Tax Best Practices for Engaging with Tax Authorities in Developing Countries.  This statement is designed to enhance cooperation, trust and confidence between tax authorities and international business.  Key observations include:

  • Each of the 10 Best Practices directs that “Business should” or “Business may.”  Accordingly, it is written from the perspective of business directives.  There are no views or statements addressing Best Practice methodologies to be conducted by tax administrations.
  • The last Best Practice states: “Business should consider how best to explain more fully to the public their economic contribution and taxes paid in the jurisdictions in which they operate, where they determine that such explanation would be helpful in building trust in the tax system.”  This statement integrates the concepts of economic contribution and taxes paid with public trust.  Additionally, there are no references to arms-length principles or analysis of functions, assets, or risks.  It is important to note that taxes paid in different jurisdictions arise from very complex laws and regulations that are different in every jurisdiction, thus making it difficult for the public to draw insightful and relevant conclusions.

BIAC Statement of Tax Principles for International Business.  Noted statements include:

  • As a tax training principle, international business should only engage in tax planning that is aligned with commercial and economic activity and does not lead to an abusive result.  There is an explicit reference to economic activity, but a lack of terminology referencing arms-length principle or transfer pricing functions, assets or risks.
  • A Transparency and reporting principle states: “Where they determine such explanations would be helpful in building public trust in the tax system, they should consider how best to explain to the public their economic contribution and taxes paid in the jurisdictions in which they operate.”  This statement mirrors that from the Statement of Tax Best Practices noted above.

BIAC Comments on the OECD Draft Handbook on Transfer Pricing Risk Assessment, published on 30 April 2013.  This is a very informative document that outlines many of the issues being considered by the OECD, and provides a thoughtful reference for discussions going forward.  Some key  statements include:

  • The risk assessment should not exceed 6 months.
  • A “low risk” status can bring tangible benefits in terms of a reduced documentation requirement as well as efficiencies in the overall audit process.
  • A “deep dive” audit is not always required.
  • The first step in transfer pricing risk assessment should consider how the business generates profit, its approach to tax planning, its supply chain and the legal environment in which it operates.
  • “From a Transfer Pricing Risk Assessment perspective, we are very keen to see the cooperative compliance approach endorsed early in the Handbook, as a precursor to narrower assessment of transfer pricing risk.”
  • “We are concerned that the overall tone and focus of the Handbook could result in a negative and sceptical view of taxpayers.”
  • We would be particularly concerned if the use of such subjective language (i.e. large, small and material payments, high-tax and low-tax jurisdictions) led to tax administrations ignoring the arm’s-length principle.
  • “Indications of profitability, effective tax rate and comparative profits of related parties are concerning as the implication may be that the transactions are inappropriate.”
  • Any risk assessment report should be shared with the taxpayer.

The Appendix provides specific comments to the related paragraphs within the Handbook.  Two examples from Chapter 1, par. 9 are cited for reference:

  • Shifting income into jurisdictions where it will be lightly taxed or engaging in related party transactions designed to erode the local country tax base-shifting income is an unhelpful phrase.
  • We would welcome clarification that income should be taxed where the functions/assets/risks are performed.

The BIAC comments should be read to better understand the context of the current transfer pricing environment, and how proposals will affect MNEs and tax administrations in the future.

Category:

Tax Risk Management, Transfer Pricing

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OECD Exchange of tax information portal

As a follow up to the OECD G20 Report post on 8 September, information about the Exchange of Tax Information Portal is provided for further reference.  The respective jurisdiction can be selected, with agreements available via PDF files.  This site will be even more useful as countries complete the relevant Peer 1 and Peer 2 reviews.

The Exchange of Tax Information Portal is an initiative of the Global Forum on Transparency and Exchange of Information for Tax Purposes.  The Global Forum conducts peer reviews of its member jurisdictions’ ability to co-operate with other tax administrations in accordance with the internationally agreed standard. The standard provides for exchange of information on request where it is foreseeably relevant to the administration and enforcement of the domestic tax laws of the requesting jurisdiction. Effective exchange of information requires that jurisdictions ensure information is available, that it can be obtained by the tax authorities and that there are mechanisms in place allowing for the exchange of that information. The Global Forum’s peer review process examines both the legal and regulatory aspects of exchange (Phase 1 reviews) and the exchange of information in practice (Phase 2). The EOI Portal will track the development of these peer reviews, including changes that jurisdiction’s make in response to the Global Forum’s recommendations.  The Portal can be accessed from the following link:

http://www.eoi-tax.org/jurisdictions/AR

The Exchange of Tax Information Portal site should be used, and shared, for valuable reference on this important and current initiative.

Category:

OECD / UN, Tax Risk Management

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Meetings: team collaboration for success

Meetings are designed to be collaborative and solution oriented, with all members of the team aligned going forward.  The author of this article, Fed Kofman, has provided a valuable approach to meetings, with all attendees actively participating and contributing to the overall objective.  The article is thought provoking and insightful to further Best Practices.

http://www.linkedin.com/today/post/article/20130827185129-36052017-put-your-meeting-on-the-wall

Fred Kofman, Ph.D. in Economics, is Professor of Leadership and Coaching at the Conscious Business Center of the University Francisco Marroquín and a faculty member of Lean In. He is the author of Conscious Business, How to Build Value Through Values (also available as an audio progra

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Leadership

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China APA Report 2012: More APAs

http://www.chinatax.gov.cn/n8136506/n8136608/n9947993/n9948014/n12360820.files/n12360827.pdf?goback=%2Enmp_*1_*1_*1_*1_*1_*1_*1_*1_*1_*1#%21

THe 2012 Annual Report outlines China’s Advance Pricing Agreement (APA) process, in addition to statistics for 2005 – 2012.  The agenda of the report includes:

  • APA Program definition and advantages
  • Legislation and Development of APA program
  • APA Procedures
  • Taxpayers’ Rights
  • Statistics and Contacts
  • Appendices, including formal meetings and applications

A Best Practices methodology addressing APA’s should be outlined in the global Tax Risk Framework for every multinational corporation.  This methodology will summarize some of the following points:

  • A description of the decision matrix for an APA and its implementation
  • Preference for unilateral or bilateral APAs
  • Implementation of global/regional/country proactive and/or reactive risk management tools
  • Outline of significant jurisdictions, timelines, work plan, and accountability for implementation
  • Integral coordination with tax counsel, and other functional business units
  • Review plan for an APA methodology in today’s rapidly changing tax environment (evidenced recently by the change in administrative leadership for the India APA program)
  • Review of applicable gaps that may exist to retrieve information readily for proactive, or reactive, APAs

Tax jurisdictions, and MNEs, are increasing their focus on APAs amidst a trend of growing uncertainty and complexity in international transfer pricing principles.  The China APA Report provides good preparation for a better understanding of the complex, and lengthy, preparation needed by all parties to obtain an APA.

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Tax Risk Management, Transfer Pricing

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Presentation Skills, A Valuable Leadership Attribute

Presentation and negotiation skills are two critical factors that  distinguish an exemplary leader.  Emphasis on these valuable personal attributes should be addressed by everyone continually, and formally reviewed once or more annually to measure success.

This post will address some ideas for the use of presentation skills, with recommended sources of reference.  My prior post, 14 August, discusses negotiation skills and tools for development.

Suzanne Bate’s books and personal coaching camps are highly recommended, with a link provided to her informative website.   I have also updated her power speaker blog on my Recommended Links page. I can personally attest to the valuable lessons learned from her personalized classes.

http://www.bates-communications.com/our-people/suzanne-bates/

Suzanne is author of Speak Like a CEO: Secrets for Commanding Attention and Getting Results (McGraw Hill), which went to #6 on the bestseller charts on amazon.com in 2005. The book has also been published in 5 languages including Chinese, Russian and Indonesian.  Suzanne has since published two more books, Motivate Like a CEO: Communicate Your Strategic Vision and Inspire People to Act!, and Discover Your CEO Brand: Secrets for Embracing and Maximizing Your Unique Value as a Leader, with McGraw Hill, and both books have become business best-sellers on amazon.com.

Some ideas for improving presentation skills include:

  • Different participants should present topic agenda items at meetings.
  • Formalizing presentation training goals in a personal development plan.
  • Organizing presentation exercises / workshops.
  • Practice telling a powerful story, starting with individual passions.
  • Review effectiveness of Power Point presentations for lessons to be learned.
  • Provide a mentor relationship.
  • Encourage individuals to sign up as presenters at relevant conferences.
  • Discuss Best Practices in company publications, providing encouragement for others.
  • Develop a source of Best Practice presentation resources, including those of Suzanne Bates.

The above references and ideas will hopefully provide inspiration for current and future leaders.

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Leadership

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The Art of Negotiation: Improve your leadership skills

Negotiation is an art and acquired skill; as such it should be a continuous journey for every tax executive.  Negotiation is used by everyone every day, personally and professionally.  For example, it can be used to develop a win-win result in cross-functional issues with a geographically diverse team or equally in discussions with tax authorities to concisely explain transfer pricing concepts.

In today’s world of tax subjectivity and controversy, negotiation is a requisite (and often neglected) skill for local, regional and global tax teams, as well as other leaders in the business.  Conveying technical tax terms and complicated transactions simply, succinctly and convincingly is a leadership skill that becomes more important as one’s career progresses.  Notwithstanding this necessity, negotiation is a skill that is not an integral part of everyone’s development program.

Books, presentations and conferences are focused on negotiation, and I will pass along some tremendous resources I have used that are easy to read and implement daily.  It is also fun to see  the results!  Gerry Spence, a U.S. renowned trial lawyer, has written the following two books for your consideration:

  • How to Argue and Win Every Time – At Home, at Work, in Court, Everywhere, Every Day
  • Win Every Case: How to Present, Persuade and Prevail – Every Place, Every Time

I highly recommend the above resources, related articles posted herein, and look forward to your ideas on this important leadership topic.

Cover of "How to Argue and Win Every Time...

Cover of How to Argue and Win Every Time

Please ensure you, and your teams, have a negotiation goal for 2013!

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GAAR: Poland’s reintroduction

Click to access com_2012_722_en.pdf

Poland’s Minister of Finance plans to reintroduce a general anti-abuse rule (GAAR).  GAAR was in brief existence from 2003-2004, however the vague principles led to its removal.

The GAAR reintroduction follows the European Commission’s recommendation in December 2012, with a link attached for reference.  The European Commission Initiatives, Section 8, Recommendation on aggressive tax planning, states “The Commission also recommends a common GAAR.  This would help to ensure coherence and effectiveness in an area where Member State practice varies considerably.”

The GAAR proposal would apply to all types of taxes, with a 30% penalty of avoided tax via a “tax avoidance” transaction.  Appeal provisions are envisioned, in addition to advance rulings, although the time and expense for advance certainty may prove to be impractical.  A GAAR Council would provide an “expert” GAAR opinion that is not binding on the tax authorities.

Poland’s GAAR proposal should be analyzed for Best Practices, coupled with insights from prior posts: EY GAAR survey (7 August) and UK Finance Act 2013: GAAR has arrived (21 July).

It is hopeful that Poland will focus on learnings from the original GAAR introduction, as well as gain insight for Best Practices from other countries that have adopted a fair, and effective, GAAR.  It will be important to observe how the new GAAR legislation will correspond, or override, its double tax treaty provisions, and if the burden of proof will reside with the taxpayer and/or the tax authorities.

Most importantly, Best Practices should be continually reviewed, and revised,  for inclusion of new GAAR proposals and principles that are an integral part of the global Tax Risk Framework.  As stated in the European Commission report, each country’s practice is , and will continue to be, significantly different.  Robust documentation, in proactive tax risk management and planning memorandums, will provide directly relevant evidence to defend the subjective principles and guidelines of GAAR.

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Tax Risk Management

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U.N. Committee of Experts on International Cooperation in Tax Matters: update

http://www.un.org/esa/ffd/tax/

The U.N. Committee of Experts on International Cooperation in Tax Matters (U.N. Committee ) is responsible for drafting the U.N. model tax treaty and the Practical Manual on Transfer Pricing for Developing Countries.  The U.N. Committee’s work on international tax and transfer pricing developments should be watched closely by the international tax community.  Additionally, developments on important topics should be compared with that of the OECD, including its Revised Draft on Transfer Pricing Aspects of Intangibles (03 August post), White Paper on Transfer Pricing Documentation (31 July post) and the Base Erosion and Profit Shifting Action Plan (19 July post).

The attached link provides reference to its provisional agenda for the 21-25 October 2013 session, the appointment of 25 members to the U.N. Committee for a 4-year term expiring on 30 June 3017 and the U.N. Model Double Taxation Convention.

The 9th session of the U.N. Committee will address U.N. Model Tax Convention issues, including the following:

  • Article 4 (Resident): Application of treaty rules to hybrid entities
  • Article 5 (PE), including international VAT cases
  • Article 7 (Business Profits): Force of attraction principles
  • Article 9 (Associated Enterprises): Commentary update
  • Article 26 (Exchange of information)
  • Other topics, including provision on taxation of fees for technical services, issues for the next update of The Practical Transfer Pricing Manual for Developing Countries, and The Manual for Negotiation of Bilateral Tax Treaties between Developed and Developing Countries.

The 25 members were appointed by U.N. Secretary-General Ban Ki-moon and will act in their personal capacity.  A detailed biography of each member is included in the press release; a listing of their name and current position is provided herein for quick reference.

  1. Mr. Khalid Abdulrahman Almuftah, Deputy Director, Revenues and Tax Dept., Ministry of Economy and Finance, Qatar
  2. Mr. Mohammed Amine Baina, Chief, Division for International Cooperation, Dept. of Taxation, Ministry of Economy and Finance, Morocco
  3. Ms. Bernadette May Evelyn Butler, Legal Adviser, Ministry of Finance, Bahamas
  4. Mr. Andrew Dawson, Head, Tax Treaty Team, HMRC, UK
  5. Mr. El Hadj Ibrahima Diop, Director of Legislation and Litigation Studies, Ministry of Economy and Finance, Senegal
  6. Mr. Johan Cornelius de la Rey, Legal Officer, Legal and Policy Division, South African Revenue Service (SARS)
  7. Ms. Noor Azian Abdul Hamid, Director, Multinational Tax Dept., Inland Revenue Board (IRBM), Malaysia
  8. Ms. Liselott Kana, Head, Dept. of International Taxation, Internal Revenue Service, Chile
  9. Mr. Toshiyuki Kemmochi, Director, Mutual Agreement Procedures, National Tax Agency, Japan
  10. Mr. Cezary Krysiak, Director, Tax Policy Dept., Ministry of Finance, Poland
  11. Mr. Armando Lara Yaffar, Director General, Int’l Affairs, Dept. of Revenue, Ministry of Finance and Public Credit, Mexico
  12. Mr. Wolfgang Karl Albert Lasars, Director, International Tax Section, Federal Ministry of Finance, Germany
  13. Mr. Tizhong Liao, Deputy Director General of Tax Treaty, Dept. of International Taxation, State Administration of Taxation, China
  14. Mr. Henry John Louie, Deputy to the Int’l Tax Counsel (Treaty Affairs), U.S. Dept. of the Treasury
  15. Mr. Enrico Martino, Head, International Relations, Dept. of Finance, Ministry of the Economy and Finance, Italy
  16. Mr. Eric Nii Yarboi Mensah, Chief Tax Treaty Negotiator, Ghana Double Tax Treaty Convention Team
  17. Mr. Ignatius Kawaza Mvula, Assistant Director, Zambia Revenue Authority
  18. Ms. Carmel Peters, Policy Manager, Inland Revenue, New Zealand
  19. Mr. Jorge Antonio Deher Rachid, Tax and Customs, Embassy of Brazil, Washington, D.C.
  20. Mr. Satit Rungkasiri, Director General, Revenue Dept., Ministry of Finance, Thailand
  21. Ms. Pragya S. Saksena, Joint Secretary, Tax Policy and Legislation, Central Board of Direct Taxes (CBDT), Dept. of Revenue, Ministry of Finance, India
  22. Mr. Christoph Schelling, Head, Division for International Tax Affairs, State Secretariat for Int’l Financial Matters, Swiss Federal Dept. of Finance
  23. Mr. Stig B. Sollund, Director General and Head of Tax Law Dept., Ministry of Finance, Norway
  24. Ms. Ingela Willfors, Director, Int’l Tax Dept., Ministry of Finance, Sweden
  25. Mr. Ulvi Yusifov, Head, Int’l Treaties Division, Int’l Relations Dept., Ministry of Taxes, Azerbaijan

It will be interesting to observe the interaction of new U.N. Committee members, and most importantly the initiatives addressed against the backdrop of the OECD’s recent developments.

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OECD / UN, Tax Risk Management, Transfer Pricing

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