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The European Commission has told the UK and Luxembourg to amend their tax legislation or risk being taken to the ECJ.

Russian president Dmitry Medvedev has signed reforms to the Russian corporate tax regime after receiving the necessary approval of the Federation Council.

Nancy Mehlman has become a partner of Simpson Thacher Bartlett's tax practice in the firm's New York office. Her practice focuses on tax issues in M&A, joint ventures and formations of private equity funds.

Canadian companies will pay less tax next year despite no emergency tax cuts, a government paper released on November 27 confirmed.

Welcome to International Tax Review's guide to intellectual property and tax for 2008. It is probably not a coincidence that in recent years significant transfer pricing disputes in Australia, Canada and the US have occurred in the IP-rich industry of pharmaceuticals. Taxpayers need guidance from their advisers on how to deal with the tax aspects of IP properly and the most appropriate approaches to adopt when presenting the results of transactions to the tax authorities. It is in this context that International Tax Review co-publishes the seventh edition of its guide to intellectual property and tax with leading advisers: Ernst & Young Shinnihon Tax, Garrigues and NERA Economic Consulting. It is the 46th in the Tax Reference Library series.

By Emmanuel Llinares, Takefumi Suzuki and Sylvain Gilibert of NERA

By Luis Liñero and Juan Carlos Molina

The Technical Explanation provides limited guidance on the Fifth Protocol to the Canada-US treaty, say Jeffrey Trossman and Jesse Brodlieb of Blake, Cassels & Graydon

Marie-Laure Hublot Nicolas Jacquot The French tax authorities have announced that they will not be introducing for the time being new transfer pricing documentation requirements, as anticipated for a few months. The first draft legislation, circulated at the beginning of this year, and the second draft issued last October, have raised too many criticisms from the business community.

Rajendra Nayak Ganesh Pai The Delhi income tax appellate tribunal in the case of Fugro Engineers BV v ACIT (2008-TIOL-502-ITAT-DEL) recently examined whether a permanent establishment (PE) would be constituted where the activities of foreign enterprise were carried on in India for less than 183 days. Fugro Engineers BV was a company incorporated in the Netherlands which was engaged in the business of providing geo-technical services and undertaking geo-technical and geo-physical investigation at drilling locations of its customers. It entered into three independent contracts with three different Indian companies for undertaking investigation activities and for provision of services.