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Malgorzata Sobonska The amendments to the Polish tax code (Tax Ordinance) which came into force from July 1 2007 caused quite important changes in the process of obtaining advance tax rulings. Until June 30 2007 rulings were issued by the local tax offices and if the taxpayer was not satisfied with the rulings, they were able to appeal the rulings to the tax chamber.

Israel's innovative entrepreneurship and pioneering technologies makes it attractive for capital investments. This article is one of a series of articles aimed at discussing the unique features of high-tech companies in Israel and the main tax considerations that should be considered when acquiring such companies.

Rajendra Nayak Ganesh Pai The Supreme Court (SC) of India in the case of DIT v Morgan Stanley & Co (292 ITR 416) recently examined certain issues relating to taxation of a foreign company in India. Morgan Stanley (MS) is an investment bank incorporated in the US and provides financial advisory services. It has a subsidiary in India, Morgan Stanley Advantage Services Private (MSAS) which provides support to the group's front office functions in their global operations.

Helsinki EU member states can operate tax systems that discriminate against a subsidiary and their parent company established in another member state.

Fernando Cruz and Lavinia Santos highlight how the tax authorities are increasing their scrutiny of transfer pricing arrangements

Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Merger $38.1 billion Rio Tinto Alcan Goodmans (Yi Wen Hsu) Merger Transocean ($31.7 billion) GlobalSantaFe ($17 billion) Transocean GlobalSantaFe Baker Botts Skadden, Arps, Slate, Meagher & Flom Acquisition $16.8 billion Danone Royal Numico De Brauw Blackstone Westbroek Allen & Overy Acquisition $16.3 billion Akzo Nobel ICI Slaughter and May (Jeanette Zaman, Tim Woodthorpe) Freshfields (Robert Kent, Arun Birla) Acquisition $16.2 billion Imperial Tobacco Altadis Urìa Menéndez (Rafael García Llaneza) Garrigues Acquisition $15.6 billion Continental Siemens VDO Automotive Freshfields Bruckhaus Deringer (Ulrich Blaas) Hengeler Mueller (Martin Klein) Acquisition $7.9 billion Hypo Real Estate Depfa Freshfield Bruckhaus Deringer

Sue Bonney KPMG has announced that the head of its UK tax practice, Sue Bonney, will be in charge of tax for its European firm. KPMG is in the process of merging its British, German and Swiss operations. The Dutch firm is shortly to vote on its inclusion.

Jack Cummings Edward Tanenbaum IRS Notice 2007-57 adds a new category of listed transaction that involves loss importation. The technique involves the most elementary of planning techniques: the domestic taxpayer arranges to reflect on its US income tax return the loss leg of a hedge entered into by a foreign entity. In order to avoid also reporting on its US return the gain leg of the hedge, the taxpayer insures that the foreign entity is a corporation for US tax purposes when it recognises the gain. Finally, to close the loop, it is necessary for the US taxpayer not to own the foreign entity long enough as a corporation to have to report its income under subpart F.

There has been a long-running dispute on the dedutibility of hedging cost against premium derived from warrant issuances for Taiwan tax purposes. Previously, 25% income tax was levied on the warrant premium after accounting for origination costs rather than on the gains from the issuance of warrants. The rationale behind the foregoing tax treatment was based on the concept that capital gains from the trading of securities are tax-exempt whereas capital losses may not be tax-deductible.