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By Ralph Cunningham

Ellie Patsalos Deloitte has made a series of key tax appointments worldwide. The firm has recruited new partners in China, the UK and Switzerland.

An international tax associate has been promoted to the partnership at Latham & Watkins.

Daniel Armesto Antonio Matute Nárdiz The European Commission has opened a formal investigation under EC treaty state aid rules into a provision of the Spanish corporate income tax law (article 12.5) that allows Spanish companies to take tax deductions deriving from acquiring a stake in non-Spanish companies. According to it, any Spanish taxpayer (company or permanent establishment) may depreciate for tax purposes the investment in a subsidiary up to the amount of the subsidiary's goodwill implicit in the price paid for it. This so-called financial goodwill is determined as the positive difference between that price and the market value of the underlying assets of the subsidiary; in other words, it is the part of the purchase price of the shares in a company that exceeds its equity and the latent capital gains attributable to particular assets. The tax deductions require the acquisition of a significant shareholding (5% or higher) in a foreign company and are taken on a straight-line basis over the 20 years following the acquisition.

Heiko Stoll of Simmons & Simmons assesses particular aspects of the Business Tax Reform Act and discusses the problems in its wording

Irina Pushkina Nina Budazhapova One of the hot topics in Russia is the unclear application of clarifications issued by Russian authorities in favour of taxpayers, in other words, whether the tax authorities are obliged to follow such clarifications or not. According to the international practice, obtaining a binding ruling is always beneficial for the taxpayer since it provides clarity and should generally remove the risk that the tax authorities will try to charge the taxpayer with additional taxes and impose fines and penalties for related underpayment of taxes. Russian legislators are making efforts to approach the international clarifications practice. However, the position of taxpayers who obtain clarifications issued by the Russian authorised bodies is still unstable.

Roberto del Toro José Antonio González Mexico continues its efforts to improve the commercial relationship with other countries through the negotiation of tax treaties for the avoidance of double taxation.

It all happens on January 1 2008. If Germany is remembered for anything else in 2007, it will be remembered for the business tax reform that takes effect at the beginning of next year. The changes are truly comprehensive, ranging from a cut in the corporate tax burden to amendments to transfer pricing rules. This doesn't affect Germany's annual tax legislation that Parliament approved in November.

There is no silver bullet for capturing brand value, believe Alexander Voegele and Richard Sedlmayr of NERA Economic Consulting