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The Warsaw office of Baker & McKenzie has announced the launch of Baker & McKenzie Doradztwo Podatkowe Sp z o o, a company set up to provide tax consultation services. The new company will operate from the law offices of Baker & McKenzie Gruszczy´nski & Partners.

After years of promising such a step, the Internal Revenue Service (IRS) has issued Revenue Procedure 2005-12 revising its pre-filing agreement (PFA) programme to provide for advance rulings on whether a taxpayer has a permanent establishment (PE) or a US trade or business (USTB).

Two important decisions on the judicial approach to the construction of taxing statutes were handed down on November 25 2004. The cases confirm the following points in connection with the construction of a taxing statute:

The Norwegian parliament passed a new tax reform in December 2004. A central part of the reform is the so-called "Exemption Model", that is, granting most corporate shareholders exemption from taxes on gains and dividends on shares, including the withholding tax on dividends.

When dealing with the Netherlands, entities that are tax transparent in their home jurisdiction often find that they are regarded as taxable entities for Dutch tax purposes. The reason for this is that, in the Netherlands, a foreign entity's tax status is determined on the basis of the civil laws of its country of residence, its articles of association or the contractual arrangements governing its existence, as well as the Dutch tax rules. In December 2004, the Dutch tax authorities issued new guidelines to determine the tax status of most types of foreign entities that seek to earn income from business activities or passive investments. The guidelines distinguish between entities that are comparable to a Dutch limited partnership (commanditaire vennootschap or cv) and other types of entities. A limited partnership type of entity is only tax transparent if the admission and substitution of partners is subject to the consent of all partners. In respect of other types of entities, the guidelines provide for four tests:

In 2004 tax authorities around the world increased their focus on transfer pricing and tax compliance, the European Court of Justice continued to exert pressure on EU member states' tax systems and the US Congress passed significant corporate and international tax reform. Simon Briault gets the views of tax professionals as they peer into their crystal balls for what 2005 has in store.

George W Bush: Wants to reform the US tax code President Bush signed an executive order on January 7 2005 to set up his Advisory Panel on Federal Tax Reform that will provide advice on ways to amend the US tax code including ways to encourage savings and investment.

A process involving financial ratios can evaluate, on a regional basis, the existence of task risk and opportunities for tax process improvements, explains Franco Antognini of Ernst & Young

Although value-added tax is usually relevant to outsourcing, there are plenty of other tax issues to consider, explain Iain Scoon and Stephen Pevsner of Shearman & Sterling

The new year has just begun and already the European Commission has published two pieces of research on company tax. And despite the low number of participants in each survey, the Commission believes they reflect enough support for increased corporate tax cooperation.