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Chasing tax evaders, sharing intelligence and enforcing the law are all part of the day job for Stefano Gesuelli, head of Italy’s tax police. In an exclusive interview with Jack Grocott, he opens up to the workings of his unit and sends a warning to taxpayers that there is no place to hide.

Herbert Smith alliance firm, Stibbe, has added Linklaters' local tax head to its new office in Luxembourg.

PwC US has announced two new hires in New York.

A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to taxrelief@euromoneyplc.com

Ronald Parks Doan Van Ngoan The quick answer from shipping lines is probably, no.

Edward Tanenbaum Tola Ozim Ronald Dabrowski, the deputy associate chief counsel (international technical) at the Internal Revenue Service (IRS), has provided taxpayers with the welcome news that a substantial business activity safe harbour, which had been removed from recent anti-inversion regulations, would likely be revived in final regulations still to come. Section 7874 generally applies to prevent entity inversions or expatriations by taxing inversion gain or, in some cases, by treating the foreign acquiring corporation as a domestic entity. A transaction comes within these rules where 1) a US corporation or partnership transfers substantially all of its property to, or becomes a subsidiary of, a foreign corporation; 2) the owners of the US entity acquire at least 60% of the foreign corporation by reason of their stock ownership in the US entity; and 3) the foreign corporation and its expanded affiliated group (EAG) do not have substantial business activities in the foreign country of incorporation as compared to the total business activities of the group.

Andrey Shpak Sergey Kalinin The Russian Parliament has just adopted amended rules on profits tax deductibility of R&D expenditures.

Álvaro de la Cueva On March 17 2011, the Spanish Supreme Court handed down an interesting judgment on the application of the thin capitalisation rule in situations of indirect indebtedness with a shareholder resident in a country with which Spain has signed a tax treaty for the avoidance of international double taxation. The indirect indebtedness issue has been highly debated in Spain.

Sean Foley Landon McGrew The Internal Revenue Service (IRS) recently announced the selection of Samuel Maruca as the transfer pricing director in the IRS' Large Business and International division (LB&I). The transfer pricing director position is a newly-created executive-level position that will lead the LB&I division's transfer pricing practice. The transfer pricing practice was created in the fall of 2010 as part of the realignment and renaming of the IRS Large and Midsize Business division as the LB&I division.

Miruna Enache Over the last decade, one of the main scrutiny items in tax audit cases (from a corporate income tax perspective) and the reason for tax disputes has been the deductibility of services expenses. The Romanian taxpayer has to prove its compliance with the legal requirements in this respect (having written contracts signed with suppliers and documentation to support the effective provision of the services as well as their necessity for its business). However, the tax authorities have become, in recent years, increasingly active and aggressive in this respect, focusing on intra-group administration and management expenses, where the legislation disallows the deduction of stewardship costs (including costs for administration, management, control, consultancy and other similar functions).