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PricewaterhouseCoopers' northern UK practice appointed Ronnie Pannu as head of its tax investigations group on May 21 2004. Pannu succeeds Geoffrey Baldwin, who is retiring after 26 years at the big-four firm. Before joining the firm in 1995, Pannu served as an inspector of taxes at the Inland Revenue.

Mark Penney, a tax partner at rival big-four firm Ernst & Young, joined KPMG in London on May 7 2004 to head-up the firm's international tax group. Penney specializes in cross-border mergers and acquisitions and advised on Walmart's acquisition of Asda and Scottish Power's purchase of PacifiCorp.

Although Irish tax law imposes an obligation on companies generally, and on others who pay interest to persons whose usual place of abode is outside Ireland, to withhold tax from certain payments of interest, there are extensive carve-outs from this withholding obligation in the case of outbound interest payments. Among these carve-outs, sections 246(3)(ccc) and (h) of the Taxes Consolidation Act 1997 (TCA) provide that withholding tax is not to be deducted from certain interest payments where the recipient of the interest is, by virtue of the law of a relevant territory, resident for the purposes of tax in the relevant territory. A relevant territory means a member state of the European Community (other than Ireland) or a territory with which Ireland has a double taxation treaty, for example, the US.

by Richard Collier-Keywood, UK head of tax, PricewaterhouseCoopers

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.

The UK Chartered Institute of Taxation appointed John Beattie as its new president on May 21 2004. Beattie served at the Inland Revenue before joining KPMG in 1979. Peter Kempster, a tax consultant at Nabarro Nathanson in London, was appointed deputy president. John Cullinane, a tax partner at Deloitte in London, was appointed vice president.

The government has finally published, in draft, details of the types of arrangement that will be subject to the new tax planning reporting requirements announced in the March 2004 Budget. The rules will focus initially on employment tax planning, use of financial products and VAT planning.

US taxpayers recently scored an important victory in Dover Corp v. Commissioner, which has monumental ramifications in the US tax treatment for disposing of non-US operations.

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: