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The European Commission has launched an investigation as to whether Luxembourg's 1929 legislation, which exempts holding and financial companies from corporate tax, breaches EU state aid rules.

Another principal of LECG, an economics consultancy, in London has left for Baker & McKenzie in the same city. Martin Zetter becomes a senior consultant in the transfer pricing group.

Caitriona McGonagle has been promoted to the partnership at Matheson Ormsby Prentice, an Irish law firm. She is based in New York, where she focuses on M&A, reorganizations and the structuring of domestic and international corporate acquisitions.

In Notice 2005-90, the Internal Revenue Service (IRS) addressed fears that new section 901(l)(1)(B) of the Internal Revenue Code (IRC) could prevent taxpayers from claiming foreign tax credits for foreign withholding taxes incurred on income derived through standard back-to-back computer program licensing arrangements in which the recipient of an item of income is required to make related payments with respect to positions in substantially similar or related property.

Arecent Court of Appeal case in the UK gives some guidance as to when a special purpose vehicle will be considered to be non-resident for UK tax purposes. The case itself was concerned with a tax planning arrangement in the context of the sale of shares in a family business. HMRC challenged the efficacy of the arrangements on the basis that one of the companies in the structure (Eulalia Holdings BV), managed by ABN Amro Trust Company and incorporated in the Netherlands, was not tax resident outside the UK. This would render ineffective the proposed tax planning arrangements devised by PricewaterhouseCoopers, the advisers in the UK to Mr & Mrs Wood, the owners of the family business.

According to the International Herald Tribune of February 14, the US tax authorities are offering law firms, accounting firms, banks and investment firms that put together aggressive tax schemes a chance to "come forward, pay penalties and turn over information" and avoid criminal prosecution

The Tax Court in Cape Town handed down a rather astounding judgment towards the end of last year. The consequences of this decision, unless it is overturned on appeal, will be extremely serious for many franchisees and others who rely to a great extent on licensed intellectual property.

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