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  • US law firm Milbank, Tweed, Hadley & McCloy on May 12 2004 hired two tax lawyers from Freshfields Bruckhaus Deringer to start up a new office in Munich. Rolf Füger specializes on tax and finance structuring for private equity firms. Norbert Rieger, the other hire, has a corporate tax background.
  • Mexico is now in negotiations with several countries to sign tax treaties. According to the Mexican tax authority's (Hacienda) webpage, negotiations are currently in process with the following countries:
  • When a non-resident individual is planning to make long-term investments in Spain, they should not forget to analyze the tax implications that may eventually arise for the heirs. We refer to the Spanish inheritance tax.
  • The debate on tax amnesty has been going on for more than ten years. The following initiatives are currently being discussed:
  • The UK Inland Revenue's tax avoidance regulations, published on May 17 2004, have been met with universal condemnation from tax lawyers and accountants. The draft rules require promoters of certain transactions to notify the Inland Revenue when they are made available to clients.
  • The special Canary Islands Special Zone (ZEC) tax regime has been in force since 2000 after authorization by the EU authorities
  • Last week the UK court of appeal overturned the High Court decision that would have required companies involved in the group litigation order case against the UK Inland Revenue to pursue their case individually. The group litigation order claim is based on the principles in the Marks & Spencer case, which is expected go before the European Court of Justice next year at the earliest.
  • Despite reaching agreement with Switzerland on implementing the EU Savings Tax Directive on January 1 2005, the European Commission has warned that it cannot guarantee that adequate arrangements will be in place by that date. Liechtenstein, Monaco and Andorra have yet to agree on the Directive and an offer from San Marino was said to be good, but not ideal.
  • Following the example of other European countries, Italy has adopted a special tax regime for the income deriving from the use of certain vessels, having a net tonnage higher than 100 tons, under the form of so-called tonnage based corporation tax (the Tonnage Regime), pursuant to the new articles from 155 to 161 of the Italian Tax Code (ITC), as amended
  • Non-resident companies could get more favourable tax treatment in the Netherlands after the Dutch Ministry of Finance issued a resolution on Dutch fiscal unity rules