ITS Global Dispatch, May 2011

OECD proposes clarifications to term "beneficial owner" in Model Treaty -- Norwegian court puts commissionaire structures at risk -- Australian government issues 2011-12 federal budget -- China focusing on financial services transfer pricing -- Hong Kong court issues favorable offshore profit decision -- Japan releases circular on corporate tax treatment of damages from March disaster; procedures to finalize 2011 tax reform on hold -- Brazilian government issues thin capitalization guidance -- Tax Court of Canada renders important transfer pricing decision