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William Chip: Covington & Burling has a

Toronto, where Rand and Thomson will work for Stikeman Elliott The increasing aggression of the Canadian tax authorities has led to higher-value disputes and prompted two tax litigation specialists to leave their boutique firm to rejoin Stikeman Elliott, one of the country's largest law firms.

A new internal study by the US Treasury Department has confirmed that Internal Revenue Service (IRS) agents are demanding transfer pricing documentation in many more audits. In January 2003 the IRS published an internal directive requiring its auditors to request transfer pricing documentation in all audits with international transactions. The new study compared audits before and after the directive. Before the directive, documentation was requested in 35% of the audits studied, afterwards the number rose to 55%.

In a decision that directly affects foreign corporations with US subsidiaries engaged in the solicitation of sales of tangible personal property in the US, the Pennsylvania Supreme Court in Schering-Plough Healthcare Products Sales Corp. v Commonwealth of Pennsylvania, confirmed that Pennsylvania was pre-empted pursuant to Public Law 86-272 (15 U.S.C section 381) from imposing its corporate net income tax on a company whose business activity in Pennsylvania was limited to the solicitation of sales of tangible personal property owned by its parent corporation.

The German tax authorities have cleared Haarmann Hemmelrath, a German law firm, of any wrongdoing in a potentially harmful negligence claim relating to the tax work it did for one of its clients.

Duncan Baxter, a former senior tax partner with Deloitte in Melbourne, has moved to Blake Dawson Waldron (BDW), a law firm, to lead their direct tax practice. Specializing in corporate and international tax, Baxter will focus on M&A, divestments and restructures. BDW announced the move on December 2 2004.

Pierre-Yves Bourtourault: VAT in the EU is still highly complex The French tax practice of Landwell, the PricewaterhouseCoopers-affiliated law firm, has lost a high profile value-added tax (VAT) partner to Baker & McKenzie. Thierry Vialaneix specializes in VAT advice for manufacturing, distribution, tourism, finance and media companies. He joined Baker & McKenzie's Paris office in November 2004.

The Revenue Laws Amendment Acts was passed by parliament in November 2004. These are omnibus Acts that amend a number of different fiscal Acts of Parliament (relating to areas including income tax, value-added tax, stamp duty and customs duty).

Businesses are now required to make a disclosure to HM Customs & Excise when they derive a UK value-added tax (VAT) benefit from the use of certain VAT-planning arrangements. The VAT-avoidance disclosure rules came into force on August 1 2004 and the first disclosures were due by October 30 2004.