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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

The Israeli Ministry of Finance's plan to cut the country's corporate tax rate from 36% to 30% government will occur over four years and introduce investment incentives for both foreign and domestic companies. The existing investment incentive regime will be replaced with three new regimes to encourage investment in specific regions and sectors of the economy.

The pressure to repeal tax-break legislation is now on the House of Representatives after the Senate approved the Jumpstart Our Business Strength (JOBS) Act by 92 votes to 5 on May 11 2004.

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.

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.