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On January 1 2006 the Ministry of Finance introduced two new sets of rules relating to the taxation of importation of goods to Poland. In general the purpose of the regulations is to apply a more taxpayer-friendly approach and create rules which would stop Polish importers from making customs clearances in neighbouring countries instead of in Poland. The government decided to make the changes because of the increased interest of Polish importers in the possibilities created by, for example, Czech postponed accounting system, combined with the exemption for supplies within bonded warehouses.

According to domestic regulations, contracts wholly or partially involving the transfer, assignment or licence of technology from a foreign party to a local entity, including the provision of technical, financial or advisory services falling under Argentine technology transfer regulations (for example, technical assistance and transfer of know-how), have always been subject to registration requirements with the local technology transfer authorities (National Institute of Industrial Property or INPI) to allow the deduction of the amounts accrued during a given fiscal year.

Brian Cowen, the Minister for Finance, set the scene for the Irish Budget when, at a Thanksgiving lunch to the American Chamber of Commerce Ireland, he reiterated the government's commitment to low direct corporate and income taxes as key drivers of economic prosperity in Ireland. This approach was followed in Budget 2006, which was delivered on December 7 and which was very much a "steady as she goes" budget.

The Mexico-Greece double tax treaty was published on December 31 in the Mexican Official Gazette and became effective from January 1 2006.

The Indian Authority for Advance Rulings (AAR) recently examined whether a US pension trust is entitled to claim benefits under the India-US tax treaty for income from the sale of portfolio investments in India.

Effective from December 19 2005 Royal Assent was given to legislation which amends the operation of what is known as the section 23AG foreign employment income exemption.

The criminal prosecution of tax advisers, the Pasquantino case and a toughened Circular 230 have combined to force US tax advisers to change how they deliver tax advice. Robert MacDonald and Vanessa Tollis of Gide Loyrette Nouel analyze the hazards

HMRC has closed down a tax avoidance scheme that had been disclosed to it (HMRC) under the disclosure regime brought in by Finance Act 2004. The scheme would have sought to generate losses artificially by buying and selling the right to dividends on shares.

Miroslaw Barszcz: Key role in tax compliance Miroslaw Barszcz has left the Warsaw office of Baker & McKenzie to join the Government of Poland as vice minister of finance.

Intra-group service fees are undoubtedly one of the most scrutinized items by the Swedish Tax Agency (STA) during tax audits. The continued scrutiny of intra-group service fees coupled with the STA's often controversial and sometimes erratic positions in its analyses has led to several court cases in this area. Arguably, a review of the aforementioned court cases could dishearten any fervent follower of the transfer pricing guidelines issued by the OECD (OECD Guidelines). Unfortunately for taxpayers and tax practitioners, the Swedish courts have tended to side with the STA. Nevertheless, there may be room for positive reform. A pending court case dealing with intra-group services may give the Swedish Supreme Administrative Court (SAC) an opportunity to set a positive precedent in one of the most recurring transfer pricing issues in Sweden.