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The US energy company ConocoPhillips is facing a law suit in a US district court from Oceanic Exploration Co and its subsidiary, Petrotimor Companhia de Petroleos over claims that ConocoPhillips committed tax fraud and other crimes in gaining its Timor Sea oil fields in south-east Asia. Oceanic is seeking $10.5 billion in damages.

Two months after announcing plans to address certain "inappropriate foreign tax credit transactions," (see International Tax Review, US Outbound Update, April 2004, p97), the US Treasury Department and the Internal Revenue Service (IRS) issued long-anticipated temporary and proposed regulations governing partnership allocations of creditable foreign taxes under Internal Revenue Code section 704(b). Under these regulations, an allocation of creditable foreign taxes cannot have substantial economic effect and as such the taxes must be allocated in accordance with the partners' interests in the partnership.

The US Internal Revenue Service (IRS) issued updated procedures on July 1 2004 that taxpayers can use to request advance pricing agreements (APAs). The procedures were designed to simplify the process of arranging APAs and to encourage bilateral and multilateral APAs to avoid double taxation.

The Supreme Court of India has held that business income and capital gains earned by an Indian resident from immovable property in Malaysia cannot be taxed in India under the India-Malaysia tax treaty.

Gary Richards of Berwin Leighton Paisner explores the ramifications of the UK's new transfer pricing regime, particularly for foreign groups

A test case brought by Debenhams, a UK retailer, could cost Customs & Excise as much as £300 million ($549 million) in lost revenue. The June 29 2004 High Court ruling upheld Debenhams' appeal against an earlier tax tribunal decision that said the company was guilty of avoiding value-added tax (VAT).

Capital Acquisitions Tax (CAT) is a tax imposed on gifts and inheritances (benefits), which exceed certain tax free thresholds. The recipients of benefits are primarily accountable for the tax. An exemption applies to benefits passing between spouses; all other benefits are taxed at 20%.

The Brazilian tax authorities have for the past few months issued a number of rulings designed to preserve and/or modify the related tax base. Some recent rulings worth mentioning are the following:

Russia has revised the list of taxes applicable in the country. On July 7 2004 the Duma passed in the third and final reading a draft law introducing modifications to Parts I and II of the Tax Code. The law is scheduled to enter into force on January 1 2005.

Baker's dozen: the 12 new partners Jesus Alvarado focuses his practice in tax planning and tax consolidation in high tech, telecommunications and entertainment.