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  • The French multinational Vivendi Universal on June 1 2004 lost a US court battle over disputed tax payments linked to the group's €12.4 billion ($15 billion) acquisition of USA Networks more than two years ago. The court ruled that Vivendi Universal should make multi-million dollar payments to cover tax liabilities incurred by IAC, the interactive group, on preferred shares held in Vivendi Universal Entertainment, the joint venture company created by the USA Networks transaction.
  • A test case brought by Debenhams, a UK retailer, could cost Customs & Excise as much as £300 million ($549 million) in lost revenue
  • Mohamed Al Fayed, the boss of the UK department store Harrods, on June 29 2004 lost his appeal to overturn a Scottish court ruling which removed his special tax status. Al Fayed, who plans to appeal the decision in The House of Lords, said the case could have implications for taxpayers who enter into agreements with the Inland Revenue.
  • Patrice Lefevre-Pearon, a French tax expert formerly at law firm De Pardieu Brocas & Maffei, has moved to US firm Morgan Lewis & Bockius. Lefevre-Pearon took two associates with him to join the 15-lawyer Paris office of the firm and will focus on domestic and international tax.
  • Colombia's new transfer pricing rules set out clearly what is expected of taxpayers, according to Ricardo Rosero, Bernardo Solano, and Fabián Alfonso of BaseFirma
  • The number of EU member states increased from 15 to 25 on May 1 this year. In a single move, the opportunities to structure investments for multinational groups in Europe multiplied, according to Götz Wiese and Henrik Lay of Latham & Watkins
  • Caroline Silberztein, head of transfer pricing at the OECD, and Donald Korb, chief counsel of the US Internal Revenue Service, are two of the big names down to speak at International Tax Review's Global Transfer Pricing Forum 2004 in Berlin. The event takes place at the Ritz-Carlton hotel on Wednesday September 29 and Thursday September 30.
  • The Russian Taxes and Levies Ministry is paying closer attention to so-called tax optimization schemes in the country. The Ministry plans to issue about 20 regulations listing typical tax evasion schemes in certain branches of the economy. The Ministry has already issued tax evasion regulations regarding the oil and construction industries.
  • The Interest and Royalty Directive of June 3 2003 was amended at the end of April 2004 in the context of the EU accession of 10 new member states. The amendment was necessary because the directive, which provides for abolition of withholding tax on intra Community interest and royalty payments between associated companies, had not yet been adopted when the Accession Treaty was signed in Athens on April 16 2003.
  • Taxpayers in Israel can avail of an amnesty on foreign trust income and gains up to the end of 2003. But the amnesty's disclosure requirements may put some of them off, according to Alon Kaplan and Lyat Eyal, of Alon Kaplan Law Firm and Leon Harris of Ernst & Young