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Victor Miesel and Vinay Kapoor have joined the transfer pricing practice of Duff & Phelps, the financial advisory firm, in the New York office.

Lew Fernandez has become associate chief counsel, income tax and accounting at the US Internal Revenue Service. He will be responsible for providing legal advice and support on federal tax issues concerning tax accounting and other areas of corporate and individual income tax

The OECD has asked for views on comparability issues affecting transfer pricing methods. The methods were introduced by the 1995 transfer pricing guidelines. Comments can be sent until November 30 2006. The OECD made the request in the 'Comparability: Public Invitation to Comment on a Series of Draft Issues Notes' paper published on May 10.

The US Senate voted for the tax reconciliation bill on May 11, meaning only George Bush's signature is needed for the bill to become law. The Senate voted 54-44 in favour, while the House of Representatives gave a 244-185 approval on May 10. The bill, seen as a significant political victory for a President suffering low approval ratings, proposes a two-year extension on.the Subpart F exception for active financing income as well as a Subpart F exeception for cross border payments of dividends, interest, rent and royalties funded by active income.

Sixth VAT Directive – Articles 21(3) and 22(8) – National measures to combat fraud – Joint and several liability for the payment of VAT – Provision of security for VAT payable by another trader.

Failure of a member state to fulfil obligations - Directive 69/335/EEC - Articles 10 and 12 - Indirect taxes on the raising of capital - Principles of Community law relating to recovery of undue payment.

The US and Denmark have signed a new protocol to amend their bilateral income tax treaty that concluded in 1999,. The protocol eliminates the source-country withholding tax on dividends arising from certain direct investments and on dividends paid to pension funds, and reduces tax-related obstacles to trade and investment flows between the two countries

Sinead Reid has joined DLA Piper Rudnick Gray Cary's tax investigations and disputes team. Reid is an Irish-qualified barrister with six years experience in the field of indirect tax. Before joining DLA Piper, she was a senior manager in the indirect tax litigation team at PricewaterhouseCoopers in London

In its first budget, the Conservative minority government in Canada has proposed reducing the the corporate income tax rate from 21% to 19% by 2010. Jim Flaherty, the Minister of Finance, also announced the abolition of corporate surtax from January 1 2008 and a a one-percentage-point reduction in goods and services tax from July 1 2006.

The UK's controlled foreign corporation (CFC) rules are in breach of the EU principle of freedom of establishment when they seek to tax the income of subsidiaries set up in low-tax jurisdictions, according to an advocate general of the European Court of Justice in the Cadbury Schweppes case.