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  • First City Tower, 1001 Fannin Street, Suite 2300, Houston, Texas 77002-6760 US
  • Baker & McKenzie have hired three senior-level economists for its global transfer pricing practice and economics group in the US. Brian Cromwell, formerly of Ballentine Barbera, will become principal economist in the Palo Alto office. He has a particular focus on transfer pricing matters involving advance pricing agreements, audit defence, intangible property valuations, and global transfer pricing strategies. Phil Carmichael, formerly a managing director of KPMG's economics and valuation services practice in New York, joins Baker & McKenzie's economics group in the same city as a director, as does Michelle Martinez in Chicago. Martinez was KPMG in Chicago's managing director for major transfer pricing projects involving large US, European and Asian multinational clients.
  • New CFC (controlled foreign company) rules entered into force in Sweden on January 1 2004. The rules apply to fiscal years beginning after December 31 2003. This means that for companies (or individuals) with a fiscal year of 1 January to 31 December, 2004 was the first year when the new rules were applicable and hence the companies had to disclose their holdings in CFC in their tax return 2005. For companies with other fiscal years they must normally disclose their holdings in CFCs for the first time in their 2006 tax return.
  • Sed Crest finds out why tax directors are stretched too thinly, whether they are happy with tax services they receive and where they can improve
  • The rise in Ireland's corporate tax rate has not stopped companies establishing operations there. David Smyth, Joe Bollard and Rory MacIver of Ernst & Young discuss why the rate went up and look back over the three years since the new rate was introduced
  • International companies should examine the provisions of the savings tax agreement between the EU and Switzerland to benefit from the reliefs it contains, believe Armin Marti and Anna-Maria Widrig Giallouraki of PricewaterhouseCoopers
  • Freedom of establishment – Tax legislation – Tax on company profits.