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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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David Mayo has Paul, Weiss in New York as a partner in the tax partner. He had previously been a partner of Gibson, Dunn & Crutcher for more than eight years.

The Chilean IRS confirmed through a couple of recent rulings that the legal provision which prevents the IRS from exercising its authority to appraise the values used in a transaction within a reorganization process is applicable to non-Chilean entities.

In the context of the application of Middle East regional tax treaties and the potential conflict between regional taxing systems and standard tax treaty language, at the heart of the debate about whether regionally-based businesses qualify as 'residents' for treaty purposes, and of considerable interest to regional businesses with historic and significant trade links with the sub-continent, is the application of the Indian tax treaties in the region, particularly India's treaty with the UAE. In this context it is interesting to note the decision of the Income Tax Appellate Tribunal in Mumbai in India.

New tax treaties for the avoidance of double taxation between Austria and Lithuania, Mexico, Moldova, Poland and San Marino entered into force on January 1 2006; the tax treaty with Switzerland shall be amended with effect as of the same date.

Only the tax departments that stay informed, collaborate in IT decision-making, and focus on the business issues will benefit from the technological change that service-oriented architecture is bringing, says Vertex