NEW YORK, March 24 /PRNewswire/ -- What are the most challenging international tax issues for corporate tax departments? According to Tax Executives Institute (TEI) members, among the significant challenges is taxing authorities' expanded use of the concept of "permanent establishment" based on server location and transfer pricing regimes. This issue was focused on when a group of TEI members joined Thomson Tax & Accounting, a segment of The Thomson Corporation (NYSE: TOC; TSX: TOC), to discuss international tax issues and where corporate tax departments were spending significant amounts of time. "The evolution of the OECD model treaty commentary to accommodate changing forms of doing business has expanded traditional boundaries of the parameters of concepts key to determining permanent establishment concept. In turn, taxing authorities in various jurisdictions are changing their interpretations of longstanding rules associated with permanent establishment. One key challenge for tax executives working in multinational enterprises (MNEs) is keeping up with the changing rules and the planning necessary to operate in a changing environment," says Timothy McCormally, executive director, TEI. Linda Scheffel, Thomson Tax & Accounting Vice President and Publisher for Research & Guidance said, "Transfer pricing rules, especially those of non-U.S. taxing authorities, have always been a challenge even for experts such as TEI's members. In international taxation, the existence of a 'permanent establishment' ordinarily creates the right of a regime to tax an entity. Stated simply, taxing authorities will assert that a higher-level holding company (with no 'permanent establishment' in a country as permanent establishment had been defined traditionally) has a permanent establishment within the country (therefore creating the right to tax the entity) if the combination of transfer pricing rules and the newer interpretation of the permanent establishment rules renders the lower-level subsidiary lacking in entrepreneurial risk. Thomson Tax & Accounting has provided cutting-edge coverage of the changes in the concept of permanent establishment brought about by e-commerce and the issues related to servers in its industry-leading Journals and WG&L treatises including Journal of International Taxation, Kuntz & Peroni US International Taxation, and Levey's U.S. Taxation of Foreign-Controlled Businesses. In addition, Thomson Tax & Accounting's Checkpoint(R), the industry-leading online research platform, provides busy tax professionals access to a vast array of expertise through its RIA research, WG&L research and workpapers, U.S. treaties and treaty explanations, non-U.S. treaties translated by IBFD (TM), non-U.S. statutory translations for over 100 countries, Create-A-Chart, and CompareIt," said Scheffel. Bijal Sheth, Vice President, Strategic Marketing, Research & Guidance at Thomson Tax & Accounting, says, "By using Thomson Tax & Accounting's Checkpoint, corporations can research time-consuming issues like transfer pricing, collaborate on analysis planning, accelerate decision making, and share knowledge quickly to minimize risks and focus on additional strategic efforts. Even time-consuming research issues can now be researched efficiently using the Create-A-Chart function." Whether through Checkpoint or CrossBorder Solutions, the worldwide industry standard in transfer pricing compliance software, Thomson Tax & Accounting is regarded as the preeminent source of information and up-to-the minute guidance, offering a wide range of integrated resources to manage the complex regulatory requirements of Transfer Pricing. An in depth article covering this TEI panel discussion of international issues appears in the March 2008 issue of Thomson Tax & Accounting's Journal of International Taxation. TEI TEI is the preeminent association of business tax executives in North America with 7,000 members representing 3,200 of the leading corporations in the United States, Canada, Europe, and Asia. TEI represents a cross-section of the business community, and is dedicated to developing and effectively implementing sound tax policy, promoting the uniform and equitable enforcement of the tax laws, and reducing the cost and burden of administration and compliance to the benefit of taxpayers and government alike. As a professional association, TEI is firmly committed to maintaining a tax system that works-one that is administrable and with which taxpayers can comply in a cost-efficient manner. Members of TEI are responsible for managing the tax affairs of their companies and must contend daily with the provisions of the tax law relating to the operation of business enterprises. The diversity and professional training of TEI's members enable it to bring a balanced and practical perspective to business tax and tax-related financial reporting issues. The Thomson Corporation The Thomson Corporation (http://www.thomson.com/) is a global leader in providing essential electronic workflow solutions to business and professional customers. With operational headquarters in Stamford, Conn., Thomson provides value-added information, software tools and applications to professionals in the fields of law, tax, accounting, financial services, scientific research and healthcare. The Corporation's common shares are listed on the New York and Toronto stock exchanges (NYSE: TOC; TSX: TOC). Thomson Tax & Accounting is a segment of Thomson and a leading provider of technology and integrated information solutions to accounting, tax and corporate finance professionals in accounting firms, corporations, law firms and government. Thomson Tax & Accounting includes the Professional Software & Services, Corporate Software & Services, and Research & Guidance business groups. RIA (http://ria.thomson.com/) and PPC (http://ppc.thomson.com/) are both brands within the Research & Guidance business. InSource http://www.insource.thomson.com/ and CrossBorder Solutions http://www.crossbordersolutions.com/ are brands within the Corporate Software & Services business. DATASOURCE: Thomson Tax & Accounting CONTACT: Melissa Lande, 1-800-993-7600, ext. 1, , or Pam Bruno, +1-203-461-9409, , both of Lande Communications, for Thomson Tax & Accounting Web site: http://ppc.thomson.com/ http://ria.thomson.com/ http://www.insource.thomson.com/ http://www.crossbordersolutions.com/

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