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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.

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.

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.

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.

In Notice 2004-19, the Treasury Department and the IRS abandoned proposals announced in Notice 98-5 (1998-1 C.B. 334), to require foreign tax credit planning structures to satisfy a broadly worded economic-profit test and, instead, announced various specific steps to combat abusive foreign tax credit planning. In the companion Notice 2004-20, a "foreign tax credit intermediary transaction" is rejected under existing rules.

In a recent unreported judgment, the Mumbai tribunal has held that the provision in Indian income-tax law authorizing taxing a foreign company at a rate higher than the rates applicable to an Indian company is still not activated by the legislature and hence by virtue of the non-discrimination article, a foreign company cannot be taxed at the rate higher than that applicable to similarly placed Indian company.

The 2004 Finance Bill confirms that, from April 1 2004, the UK's transfer pricing rules, which until March 31 2004 applied only to cross-border related party transactions, are extended so that an arm's length price is also imposed for tax purposes on related party transactions within the UK. This includes sale of goods, supply of services including head office and management services, licensing of intangibles, financial arrangements such as related party loans and guarantees and secondment of staff.

Germany could face proceedings in the European Court of Justice (ECJ) if it fails to respond to a European Commission (EC) demand to end its exit tax on unrealized capital gains of persons who leave the country. If Germany does not respond within two months of the April 19 2004 notice the EC will be able to challenge Germany's exit tax before the ECJ.

Deduction of expenses by French subsidiaries, resulting from rebilling by foreign parent companies is likely to attract the attention of the French tax authorities. The latter may challenge the deductibility of these expenses pursuant to the specific provisions of section 57 of the French Tax Code: once the French tax authorities have proven that the French and the foreign companies are related parties, they only have to provide evidence of an advantage given to the foreign company in order for the transaction to be deemed abnormal.