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KPMG's International Corporate Tax practice is dedicated to helping companies achieve tax efficiency in their international operations. Our global network of professionals from KPMG International member firms understands key industries and their tax issues. We can help you build competitive advantage through effective tax planning and compliance advice. E-mail go-fmcorporatetax@kpmg.com

The Tax Department is currently made up by six partners and five senior associates, assisted by around 20 other tax lawyers from the offices of Madrid, Barcelona, Valencia, New York, Lisbon and Sao Paulo. The Department advises on all Spanish, Portuguese and Brazilian direct and indirect taxes, but has particular expertise in mergers and acquisitions, financial products and capital markets, international tax planning, real estate transactions and project finance, assurance and pension funds and tax investigation and disputes.

Our international tax team comprises over 50 practitioners throughout Europe. We advise on M&A tax planning, international group structuring, capital markets and banking taxes, employment taxes, real estate taxes, VAT and other indirect taxes, tax investigations and disputes, all as a matter of course. In addition, we have recognised experts in the areas of trusts and private capital tax planning, share incentives and employee benefits and onshore and offshore collective investment schemes.

IntraPrice is an independent firm specialized in offering transfer pricing services. It is well recognized for its practical approach and hands-on support tailored to the needs of each client. The company is staffed by specialists with extensive transfer pricing, international tax, economic and business experience. www.intraprice.com

In March 2004 the European Court of Justice (ECJ) invalidated a French statute that taxed the unrealized appreciation inherent in corporate stock held by long-term French resident individuals upon transfer of their tax residence from France to another country (Hughes de Lasteyrie du Saillant - Case C-9/02).

Advocate General Kokott issued her non-binding opinion in the Manninen case (C-319/02) on March 18 2004 regarding the compatibility of the Finnish tax credit system with the EC Treaty. In Finland, economic double taxation of corporate profits is avoided by crediting corporate income tax paid by the company against the income tax payable by the individual on the dividend received. The credit is denied, however, if the company distributing the dividend is not a resident of Finland.

A 0% dividend withholding tax rate in some cases is one of the features of the new protocol between the US and the Netherlands, according to Wouter van Holthuijsen and Saskia Rienks of PricewaterhouseCoopers

Regulatory changes have made the creation of a holding company in China more attractive. However, investors still need to be aware of the tax and foreign exchange rules, cautions Wendy Guo of KPMG

The first three multilateral advance pricing agreements have been concluded in Europe. Similar agreements are likely to grow in popularity, according to Dave Rutges, Eduard Sporken, Dirk Van Stappen and Pascal Luquet of KPMG