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Companies already pay top dollar if they think they're buying the next big thing. But Claire Jones finds out that they could face even greater costs if they don't consider intellectual property tax issues

Sean Foley The IRS has released Rev. Proc. 2007-23, which provides rules allowing taxpayers to change to or continue to use the Net Consideration Method with respect to a qualified patent cross licensing arrangement (QPCLA). In summary, the IRS has agreed that cross license payments for patents can be netted against each other for withholding tax and certain other tax purposes.

By Alvaro Taiar, Alcides Mariano and Ana Luiza Salles Lourenço of PricewaterhouseCoopers Brazil

On March 1 2007, in a preliminary ruling from a VAT Tribunal, the Advocate General's (AG) Opinion was delivered in JP Morgan Fleming Claverhouse Investment Trust plc and The Association of Investment Trust Companies v Commissioners of HM Revenue and Customs (Case C-363/05). The point at issue was the extent of the VAT exemption for management of special investment funds as defined by member states conferred by Article 13B(d)(6) of the Sixth VAT Directive. The exemption provided in VAT Act 1994 (Items 9 and 10 Group 5 VATA 1994) applies to open-ended collective investment schemes such as Authorised Unit Trusts (AUTs) and Open-ended Investment Companies (OEICs), but not to closed entities such as Investment Trust Companies (ITCs). The taxpayer is an ITC which receives management services from a third party which are treated as chargeable to VAT.

Monika Dziedzic Poland has signed treaties with Georgia, Iran, New Zealand and the UK. The new agreement with the UK replaces the 1976 treaty.

Niklaus Honauer and Verena Gritsch of PricewaterhouseCoopers discuss how Switzerland intends to revise its VAT regime and the EU cross-border issues that companies face

By Roberto del Toro, David Cuellar and Mario Alberto Gutiérrez of PricewaterhouseCoopers

By Marc Tahon and Marc De Muynck of KPMG Tax & Legal Advisers

Taxpayers buy, sell and reorganise companies in more and more countries around the world. Revenue authorities are rushing to put in place the most appropriate rules and regulations for those deals. International businesses require world-class tax advice to help them deal with these complex M&A tax rules.

Competition for investment and fundraising has made governments reexamine how they tax capital markets transactions. So much so, that taxpayers have to work hard to keep up with changing regulations that are making more and more economies suitable for their money. The volume of law in different countries make the easy access to high-quality knowledge and advice essential.