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The 2005 Budget Law has not provided for any tax measures of great relevance. The socialist government, in office since March 2004, has promised a major tax reform for late 2005 the features of which are not yet known

Nick Gangemi, a former tax partner at Baker & McKenzie, has joined BDO in Australia as national tax technical director

Last December the Argentine executive has promulgated the Law 25988 (passed by the Congress on December 16 2004) that enables taxpayers to recover value-added tax (VAT) paid on certain acquisitions of fixed assets and establishes a one-year extension of the unpopular financial transactions tax among other tax measures

Tom Wilson, who held senior positions at the Internal Revenue Service (IRS) in a career spanning 36 years, has joined PricewaterhouseCoopers’ San Francisco office

The Norwegian parliament passed a new tax reform in December 2004

Rick Rosas, a tax partner with PricewaterhouseCoopers in Los Angeles will be one of three people that will know the winners of the Academy Awards before they are announced during the ceremony on February 27 2005

In December 2004 the German tax authorities issued a directive addressing a judgment rendered by Germany's highest tax court in January 2003

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:

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: