Summary: 1. Treaties ‒ China / Ecuador: signed 21 January 2013 ‒ India / Sri Lanka: signed 22 January 2013 ‒ Vietnam / Morocco: effective 1 January 2013 ‒ Indonesia / Morocco: effective 1 January 2013 ‒ China / Ethiopia: effective 1 January 2013 2. Cases ‒ India: Chiron Behring • Can a German partnership claim treaty benefits under the India / Germany treaty? ‒ UK: Prudential • Legal professional privilege does not extend to accountants who provide tax advice ‒ U.S.: Amazon • Ongoing case • Calculation of buy-in payment under cost sharing agreement 3. Malaysia: employee share schemes ‒ Public ruling issued 4. India ‒ Exports of computer software • Circular issued ‒ Silicon Valley Tax Director Group • Letter to U.S. and Indian tax authorities, expressing concerns about transfer pricing disputes in India 5. Transfer Pricing: BRICS schism? ‒ BRICS countries agree to develop international tax and transfer pricing standards that take into account “the aspirations of developing countries in general and BRICS countries in particular”
