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Three advisers - Stephanie Pantelidaki, Martin Zetter and Andrew Boyle - joined the London office of Baker & McKenzie from LECG. Pantelidaki will be an assistant director, Zetter a senior consultant and Boyle an economist. Richard Fletcher made the same move in January.

The Internal Revenue Service (IRS) has just released Notice 2006-35 stating that branches of financial institutions will no longer be permitted after December 31 2006 to act as Qualified Intermediaries in countries that do not have IRS-approved "know your customer" (KYC) rules.

In a previous issue of the magazine, we analyzed some of the main features of the major tax reform that the Spanish Ministry of Finance published in January. As anticipated, some relevant modifications have been finally introduced before its submission to the Spanish parliament.

The tax authorities have released a draft circular on the taxation of internationally mobile employees. The final version will be published officially within the next few weeks. The circular brings a number of decrees from the past few years together in a single document, and so serves as a good overview of the special features of expatriate taxation.

David Rivkin's guilty plea in the case of bogus tax shelters involving former KPMG staff and bankers and lawyers, was "made out of fear and a lack of resources rather than any real guilt," according to Stanley Arkin, a lawyer for Jeffrey Eischeid, former head of KPMG's innovative strategies group. Eischeid goes on trial in the case with 17 ex-colleagues later this year.

An opinion from an advocate-general of the European Court of Justice went against provisions of the UK tax system one more time. In the FII (franked investment income) group litigation against the Inland Revenue, which involved BAT group companies, Leendert Geelhoed believed the UK's rules breach EU law because they exempt dividends received by UK resident companies from other UK resident companies from corporate tax, but impose tax on dividends from companies resident in other member states, even when credit has been given for double taxation. The opinion also held that the UK's system of advance corporation tax, which has already been abolished, was discriminatory. The taxpayers were represented by Dorsey & Whitney

Tax avoidance used to be a respectable term. It once referred to the management of a taxpayer's affairs, within the law, so they could reduce the amount of tax they paid. Now with tax authorities being more and more aggressive in seeking the money which they believe is being kept from them illegally, the mention of the term immediately puts minds some finance ministry officials around the world into fearsome mode. As tax collectors are now focused on the tax gap, they are looking at commonly used structures from a new perspective. The phrase tax planning is almost taking on a suspect connotation nowadays too.

Rupak Saha, country tax leader for GE in India, introduces this special feature on the issues taxpayers need to be aware of when doing business in India

Taxpayers should maintain accurate transfer pricing documentation to avoid attention from the revenue authorities, believe Vispi Patel and Sanjay Kapadia of RSM & Co

India's indirect taxes regime is a mish-mash of central, state and local rules. The introduction of a goods and services tax regime in 2010 should help industry understand its compliance obligations better, believes Vivek Mishra of Ernst & Young