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Taxpayers should address the tax issues relating to outsourcing early so they get the benefit of efficient services in a cost effective manner, believe Samir Gandhi and SP Singh of Deloitte Haskins & Sells

In response to taxpayer requests for guidance on the US tax treatment of cross-licence arrangements, the Internal Revenue Service (IRS) recently published Notice 2006-34, 2006-14 IRB 705, (the Notice), seeking information from taxpayers and practitioners on the substance of such transactions. Cross-licensing transactions are commonly entered into between parties who each own intellectual property (IP), often patents, and who wish to secure specified rights with respect to the IP owned by the other party. The motivations for entering into these arrangements vary, including, use of the other party's IP to develop a new product and averting potential infringement lawsuits that may arise from the exploitation of one's own IP (for example, licensing rights to a similar technology to avoid an infringement claim with respect to one's own IP).

In recent years, some cities in Mexico have become attractive for foreign filmmakers to film all kind of movies. As such, the Mexican tax authorities issued certain rules to benefit this growing industry that not only generates jobs, but also some other benefits the cities in which the film is made (for example, improvements to the railways and an increase in tourism).

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.

A recently issued notice had spurred development of China's APA programme. The programme can be useful to address not only cross-border but also intra-China transfer-pricing issues, explain Spencer Chong and Qisheng Yu of PricewaterhouseCoopers

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.

Canada's new minority government is unlikely to introduce any dramatic policy shifts so its impact on international tax issues is likely to be limited, though plenty need its attention, explains Stephen Bowman of Bennett Jones

The US IRS has hit Symantec, a US software security firm, with a demand for $1 billion. The tax bill came to $900 million with an extra $100 million in interest and penalties. Most of the charges relate to Veritas, a software company that Symantec bought in December 2004.

Are special arrangements applied in Austria to international passenger transport providers not established in that member state, who provide only occasional services there and whose turnover there is less than EUR22,000 per annum, contrary to the Sixth VAT Directive?

Sixth VAT Directive – Article 13A(1)(c) – Exemptions – Provision of medical care in the exercise of the medical and paramedical professions – Therapeutic treatments given by a physiotherapist and a psychotherapist – Definition by the member state concerned of paramedical professions – Discretion – Limits.