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Michaela Klar has joined Wolf Theiss' tax practice in the firm's Vienna office. As well as corporate tax law and international tax law, she specializes in the taxation of financial instruments. She previously worked for Freshfields Bruckhaus Deringer.

The Luxembourg Administrative Tribunal in a decision released on March 13 2006 (No 19691) clarifies when a holding 1929 company converted into a fully taxable company becomes subject to Net Worth Tax (NWT) in Luxembourg (companies benefiting from the Holding 1929 regime are exempt from this tax).

The EU's policy on transfer pricing documentation requires more information than its Dutch equivalent. Taxpayers should consider the benefits of following the European model, believe Monique van Herksen and Folkert Idsinga of Baker & McKenzie

The South African finance minister, Trevor Manuel, said on April 3 that he would soon name a task force to decide how to best implement a windfall tax on petrochemicals company Sasol. Sasol which was state subsidized, announced an increase in profits of about R2.9 billion ($480 million) because of higher oil prices in the last half of 2005. The windfall tax is popular politically because it will lead to a redistribution of income but tax professionals are concerned about its introduction. Sasol is expected to contest the committee's proposals but it is predicted the authorities will pass a law before the end of 2006.

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

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.

Laurence Toxé has become a partner on of Norton Rose in Paris. Toxé specializes in M&A, LBOs, venture capital, collective investment, media and corporate structuring, sector focus international corporate finance and financial institutions.

Petr Hájek, former head of the Czech government's business environment and legislation department, has joined PricewaterhouseCoopers, where he will work on service and client development. Hájek has negotiated with the European Commission on state aid policy and worked on bankruptcy reform.

The Indian income tax authorities have demanded Rs500 million ($11 million) from a foreign bank as a result of investigations under the transfer pricing audit regime. According to the Times of India on April 24, the tax claims the authorities have made against multinational corporations amount to Rs2.5 billion. The report said that 1,000 MNCs were investigated in 2005 and about a quarter were judged to have evaded tax.

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.