Also in this issue:

• Hong Kong
  - Court clarifies application of DIPN 21 on locality of profits issue
• Brazil
  - New law broadens transfer pricing concept of “tax haven”
• Taiwan
  - Ruling allows more creditable input VAT on merger of parent and wholly owned subsidiary
• Vietnam
  - New corporate income tax law passed
• Global Tax Alerts
  - United Kingdom: High court rules in Vodafone that U.K. CFC rules incompatible with EC law

See attached file for details.

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