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  • Australia finalized double taxation treaties with the UK and Russia on December 17 2003. The Australia-UK treaty will go into effect on 1 July. The Australia-Russia treaty became effective on 1 January 2004.
  • The US IRS appointed Nancy Jardini as head of the agency's law enforcement division on January 20 2004. As chief of criminal investigation, Jardini will direct a nationwide staff of about 4,500 employees. She replaces David Palmer, who had the position from November 2002.
  • French law firm CMS Bureau Francis Lefebvre has hired four tax specialists to expand its presence in Africa. Lamiae Homman-Ludiye, Pierre Marly, Deana d'Almeida and Jacques Isabelle, all former HSD Ernst & Young lawyers, joined the Africa section of CMS's Paris office on January 20 2004.
  • Foreign corporations that have US subsidiaries selling tangible personal property within the US may be familiar with the concept that the commerce clause of the US Constitution, which serves to limit state action to the extent that it burdens national commerce, prohibits a state from requiring sellers who have no physical presence or a de minimus presence within the state (known as remote sellers) to collect sales tax on purchases of goods shipped to in-state customers.
  • Spain has put a favourable tax regime in place for foreign employees assigned to the country, effective January 1 2004. Individuals that transfer their tax residence to Spain can opt between being subject to personal income tax as Spanish residents and being treated as non-residents, provided that they meet certain requirements:
  • Ted Keen: Pharmaceutical caompanies should use APA process GlaxoSmithKline (GSK), the world's second-largest pharmaceutical company, has rejected a claim from the US Internal Revenue Service (IRS) that the group owes $2.7 billion in back taxes and $2.5 billion in interest.
  • European law and member states’ corporate tax systems are at odds. Mark Persoff of Clifford Chance looks at recent events
  • The tax treatment of interest payments between related corporate parties and thin capitalization is set to change. Nikolaj Bjørnholm and Steen Halmind of Bech-Bruun Dragsted explain what’s in the proposed legislation
  • The 2003 Finance Act created a favourable tax status for publicly quoted property investment companies in France. Philippe Royou of Simmons & Simmons believes the advantages of corporate tax exemption and a stock exchange listing may encourage other European countries to follow France's example
  • Citigroup's global transfer pricing director, Richard M Goldberg asks where the arm's-length buck stops