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  • Some EU members have conformed with the Interest and Royalties Directive. Others will benefit from transitional arrangements. Philippe de Clippele and Benoit Verschueren of PricewaterhouseCoopers bring us up to date with the state of implementation
  • Before deciding where to locate R&D, companies need to consider which countries are the most attractive. Ken Murray and David Cobb of Deloitte provide an overview of the places with the best tax incentives for performing R&D
  • Sed Crest speaks to tax executives at multinational media companies, and their advisers, discovering their tax objectives and how they achieve them
  • The governments of the UK and Gibraltar have challenged a European Commission (EC) finding that Gibraltar's proposed corporate tax reform measures are not compatible with EU state aid rules. The two countries could take their case to the European Court of Justice after the EC declared that Gibraltar's tax system should be the same as the UK's if it is to be regarded as part of the UK for EU purposes.
  • International tax and beneficial ownership intersect when royalty payments are made cross-border. But there is no consistent definition of beneficial ownership that everyone can use, says Carlos Vargas of KPMG
  • Finland's largest law firm, Roschier Holmberg, has formed an alliance with law firms from Estonia, Latvia and Lithuania in time for those countries' accession to the EU on May 1 2004. Raidla & Partners, Lejins Torgans & Vonsovics and Norcous & Partners, all of which have tax practices to compliment Roschier Holmberg's eight-strong tax team, agreed to the alliance on April 4 2004.
  • Robert Stack: The combination broadens our reach Wilmer Cutler Pickering and Hale and Dorr will combine on May 31 2004 to create one of the largest law firms in the US. The new tax practice will have a total of 16 partners and over 30 lawyers.
  • The government of Singapore has extended tax breaks to all Singapore-based audit, accounting, and legal firms to strengthen the country's position as an international hub for headquarters operations and to encourage professional service firms that are structured as partnerships to expand their activities.
  • Two more economists have moved from the big four to a legal practice in the US, adding to the movement in the transfer pricing services market there. In April, Baker & McKenzie hired Donna McComber from Ernst & Young for its San Francisco/Palo Alto office and Thomas Respess left PricewaterhouseCoopers to join the law firm's Washington DC office.
  • The Internal Revenue Service (IRS) has released its annual report on the US advance pricing agreement (APA) programme covering calendar year 2003 (See Announcement 2004-36). This is the fifth such report and like its predecessors, contains a wealth of detail on US APAs and the IRS approach to transfer pricing.