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The Canadian revenue authority has issued a taxpayer's charter. This suggests that taxpayers would have certain commitments from the taxman. Chris Sanger, head of tax policy at Ernst & Young in the UK, speculates on what might be in a new UK version

Rob Withecombe, head of tax at Grant Thornton UK, is sceptical about the outcome of an OECD project which will risk-assess tax advisers

Viva Hammer International law firm Crowell & Moring has opened a tax consulting practice in New York. Viva Hammer joins as the first tax partner in the office.

Sean Foley US Customs and Border Protection (CBP) recently issued an informed compliance publication (ICP) containing valuable guidance on related parties pricing (Determining the Acceptability of Transaction Value for Related Party Transactions). As part of the released guidance, CBP explicitly expressed its position on the use of Advance Pricing Agreements (APAs) and transfer pricing studies to support a Customs arm's length price, as discussed below.

Roberto del Toro Francisco José Zamora Among the several anti-abuse provisions that were incorporated in the 2007 tax reform, new rules against the transferring of net operating losses (NOLs) were enacted, in specific when there is a change in the shareholders' control of an entity.

Bob van der Made On May 2007, the European Commission issued a communication on the progress made on the Common Consolidated Corporate Tax Base (CCCTB) which also includes an outline of the work still to be done. The European Commission remains committed to presenting a legislative proposal in 2008.

Stephen Nelson The PRC State Administration of Taxation issued a notice on April 4 2007 (Guoshui (2007) 403) interpreting the Hong Kong-China double tax arrangement (DTA) The notice is of relevance not just to Hong Kong tax residents, because it also is applicable to other tax treaties if the relevant issues are identical and no prior interpretation has been issued. There are many aspects in the notice that deserve attention but for the present discussion, we will focus on permanent establishment (PE).

Ricardo Zúñiga In concord with a trend of tax reform during the last months, the governments of the Central American countries have adopted or are discussing new legislation as part of an implementation programme provided for by the Free Trade Agreement between Dominican Republic, Central America and the United States of America (DR-CAFTA). New tax legislation is under discussion to comply with a preparatory schedule of regional reforms prior to engage in trade negotiations with the EU. This agreement with the EU would also include Dominican Republic and Panama as signatory countries. Other pieces of legislation would be issued with the purpose to facilitate compliance with domestic tax obligations and formal duties.

Bill Maclagan Kevin Zimka The Canadian government introduced its 2007 Budget on March 19 2007 (the budget), and dealt with a series of items in the international tax area, including matters relating to the Canada-United States Tax Convention (1980)(the Treaty). In the Budget the government announced that it was close to finalising a new protocol to the Treaty (Protocol).

By Anders Bjørn (Denmark), Henrik Lund (Denmark/The Netherlands) and Steven Tseng (China)