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Representatives of the member firms of Taxand An alliance of tax firms has come together in Europe, India and the US to provide their clients with independent tax advice on international tax. Taxand will be a non-exclusive network of tax firms which will work with each other when possible.

Andrew Needham, a former tax partner at Willkie Farr & Gallagher, has become Cravath, Swaine & Moore's first lateral hire for 62 years. His move is the first time since 1943 that Cravath, Swaine & Moore has recruited a partner from outside the firm. Needham has advised clients including Zurich Insurance Company, Midamerican Energy Holdings and Teva Pharmaceuticals. He will join his new firm on April 4 2005.

The minister of finance delivered his Budget speech to Parliament on February 23 2005. The Budget was reasonably expansionary, with additional funds being spent on social welfare and infrastructure development.

Interest on loans entered into by a foreign head office and allocated to a Russian permanent establishment (PE) is considered to be sourced from Russia under most double tax treaties (DTTs) concluded by Russia. Therefore such interest is subject to Russian withholding tax (WHT) at the rate of 20%. This rate is reduced to 0% under most DTTs (Russia's treaties with the US, UK, Luxembourg, the Netherlands and Cyprus). However, under certain DTTs (Russia's treaties with Italy and Switzerland), the WHT rate is reduced to 10% or 5% and therefore it is necessary to pay WHT.

The Philippine Chamber of Commerce and Industry (PCCI) has opposed a government tax proposal that would increase corporate income tax from 32% to 35%.

The National Tax Tribunal issued a noteworthy comment on the withholding tax treatment of a payment for software developed by a foreign company and distributed by a Japanese company. The tribunal case discusses payments for software products from the Japanese distribution company to the foreign company by classifying them into the following three types. It should be noted that the classification of the software transactions should be determined based on the facts and substance rather than contract terms.

The impact of legislative changes, the future of debt pushdown planning and a straightforward methodology for strategic tax planning are considered by Nick Woodford and Christoph Schreiber of PricewaterhouseCoopers. This article was written before the announcement of new rules in the UK Budget on March 16 2005.

Anti-avoidance and Europe dominated the discussion of international tax matters after the UK Budget. Tax advisers explain to Ralph Cunningham what the government's plans mean for their clients

Helen Wylde: thinks the revenue authorities are looking at VAT on mobile calls O2, a UK mobile phone operator, has released new software that separates business and personal mobile calls, helping tax directors comply with value-added tax (VAT) requirements.

Mukesh Bhutani: victory bodes well for similar cases Samsung, a Korean electronics company, has won a victory before a Bangalore tax tribunal on the tax implications of shrink-wrap software imports.