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George Clarke Law firm Baker & McKenzie has added extensive experience to its tax disputes practice in Washington, DC, by appointing George Clarke as a partner from Miller & Chevalier. Clarke, who was an associate at Baker from 2003 to 2008, has extensive experience in all facets of the tax dispute resolution process including litigation of civil and criminal tax matters.

Wolf Theiss will add one new tax partner and two lawyers to its ranks when it takes over Beiten Burkhardt's Warsaw office on January 1 next year. Three other partners and 37 lawyers also work in the office, which will be renamed Wolf Theiss Warsaw and will be the firm's largest outside Vienna.

New Zealand taxpayers are watching Alesco's Court of Appeal case with bated breath, as the outcome could give a big indication of the extent to which the country's general anti-avoidance rule (GAAR) can be invoked against transactions.

Charlotte Rushton, managing director Asia Pacific EMEA for the tax & accounting business of Thomson Reuters, considers the challenges facing corporate tax departments in India after the recent third annual India Tax Forum.

Cross-border transactions and interpretation of related international tax treaties often involves controversies and issues concerning interpretation of treaty provisions and thereby leads to litigation with tax authorities. A recent judgment of the Tax Tribunal (Tribunal) in India in the case of Apollo Hospital Enterprises Limited (AHEL), has given rise to a debate regarding the interpretation of the expression “may be taxed” used in the India – Sri Lanka double taxation avoidance agreement (Treaty). Sanjay Sanghvi and Ashish Mehta, of Khaitan & Co, explore the implications.

Erik Øxnevad Larsen, Deloitte The Norwegian tax authorities consider such activity to be liable for tax, however their interpretation of the Petroleum Tax Act is probably incorrect. The purpose of the Norwegian Petroleum Tax Act is to secure authorisation to tax the "core" oil activities, meaning exploration and exploitation of hydrocarbons in the seabed. However, also any activity "connected therewith" is taxable in Norway provided that such activities are performed within the geographical scope of the Act (see sections 1 and 2 of the Act).

Edwin Vanderbruggen

Hartwig Welbers, PwC The government has recently published its 2012 Corporate Tax Reform Bill with a number of important changes for tax groups. Under present law, an Organschaft subsidiary must be of German registration and be managed from Germany (the double requirement). To avoid an infringement of community law the new rule will allow companies managed from Germany to join an Organschaft as a subsidiary if they are registered in another EEA state.

Ayesha Lau

Neja Nastran, Wolf Theiss Slovenia recently enacted its fiscal reform programme, originally presented earlier this year, with effect retroactively to January 2012. The reforms are part of a broader programme initiated by the Slovenian government in other areas to encourage growth in the economy and to attract foreign investment.