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International Tax Review's 2005 Global Transfer Pricing Forum, in association with Baker & McKenzie, is being held on September 29 & 30 at the Hotel Arts in Barcelona. The event, in its fifth year, aims to build on previous successful editions in Berlin, New York, Amsterdam and Paris.

Corporate tax directors in the US are weighing up the possibilities for repatriating foreign earnings after the Internal Revenue Service (IRS) issued its latest round of guidance on a Jobs Act 2004 provision that allows companies to bring funds back to the US at a reduced rate of tax.

The UK government has disclosed its agenda on tax issues for its six-month EU presidency, which began on July 1. It will advocate movement on value-added tax dossiers and the code of conduct on business taxation. The newly implemented savings tax directive could be subject to adjustments and there will be efforts to halt European Court of Justice rulings becoming law in the member states.

Philip Baker, QC, of Gray's Inn Tax Chambers in London, considers the pros and cons

Just as this issue was going to press on July 5, the ECJ released its decision in the eagerly-awaited D case (C-376/03) concerning Dutch net wealth tax and the free movement of capital under the EC Treaty. The court ruled that the treaty does not prevent a member state from denying a non-resident who has most of their wealth in the country where they live the allowances that they grant its own residents. The court also decided that the benefits of a tax treaty between two member states do not have to be extended to a third EU member.

Haarmann Hemmelrath has bolstered its international tax practice by hiring a new partner in Paris. Jacques-Henri de Bourmont, a French corporate and international tax adviser who is also qualified in Germany, joined the firm from EY Law on June 15.

The tax and legal rulebook to facilitate cross-border mergers of companies within the EU is expanding all the time. However, Germany is one member state which still requires domestic implementation legislation, explains Jürgen Hartmann

It is important how you classify the debt in a debt transaction in the UK. You need to structure your arrangements properly so that the debt is exempt loan capital and no stamp duty is payable, explain Ian Johnson and Paul Miller of Ashurst

Global VAT obligations can overwhelm a company with no system to deal with them. Some careful planning can help companies to cope, argues Chris Walsh of Vertex

Sed Crest talks to Reuven Avi-Yonah, a former consultant to the US delegation to the OECD harmful tax competition forum, about the role of multilateral organizations in tax policy and how tax policy cooperation threatens international tax planning