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Dieter Endres The finance ministry has issued its long-awaited decree on advance pricing agreements (APA). The ground breaking novelty for the German tax scene is that the authorities seem, for the first time, to be ready to commit themselves in advance on intentions rather than facts. An APA is to be negotiated by the Central Tax Office at the request of the German taxpayer with the competent authority of the other state under the double tax treaty. This overcomes official reticence on tax deals, but does mean that APAs will be bilateral. A multilateral effect is achievable by negotiating the same agreement with each of the relevant national authorities.

The UK chancellor's Pre-Budget Report (PBR) has reversed some of the implications of Deutsche Morgan Grenfell's (DMG) victory against the UK authorities, which entitled companies to compensation for corporation tax overpayment.

The Ballentine Barbera Group, the transfer pricing unit of CRA International, has set up its first office on the continent of Europe. The firm has hired Gerben Weistra from LECG to be a director in Amsterdam. Weistra's previous experience was with PricewaterhouseCoopers and IntraPrice.

Pedro Fernandez Inmaculada Vera Serena The Tax Fraud Prevention Act, passed on November 2, will become law when the official gazette is published.

Jacek Bajson Poland's revised Personal Income Tax (PIT) will enter into force on January 1 2007.

The IRS now has broad authority to impute contractual terms and determine the ownership of intellectual property. By Ward Connolly and Barton Bassett of Fenwick & West

Including stock options in transfer-pricing analyses has long been a problem in the US. Does the FASB's new accounting standard provide the right answer? By Liga Bauer-Hoy and Kelly Russell of BBG CRA International

Welcome to the special feature on North America in the December/January issue of International Tax Review.

By Pim Fris and Jean-Sébastien Lénik of NERA Economic Consulting