In this issue:

• Technical explanation of Canada-U.S. protocol provides guidance on attribution of profits to permanent establishments and arbitration
• Singapore introduces transfer pricing reviews
• Israeli tax authorities issue circular defining TP documentation requirements
• Portugal issues APA guidelines
• U.K. tax authorities publish new transfer pricing guidance
• Taiwan approves “markup on total costs” as profit level indicator for transfer pricing
• IRS release of new cost sharing regs imminent
• Germany approves regulations on the relocation of functions
• ATO releases annual compliance program statement for 2008-09; transfer pricing continues to be area of concern
• New Brazilian law broadens transfer pricing concept of “tax haven”
• Australian high court rules ATO not required to state reasons behind transfer pricing adjustments
• Hungarian transfer pricing survey shows many taxpayers unprepared for audits
• India tribunal’s decision provides guidance on comparables

See attached file for details.

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