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  • Richard Collier-Keywood was elected head of PricewaterhouseCoopers' UK tax practice on November 4 2003. Collier-Keywood was responsible for business development and marketing and has led the UK direct tax practice since entering the partnership in 1992.
  • On November 6 2003, the United States and Japan signed a new income tax treaty and a protocol to the new treaty, and exchanged diplomatic notes concerning the interpretation of certain provisions of the treaty and protocol. The US Senate and the Japanese Diet should take up the treaty early in 2004, and ratification appears highly likely. If ratified, the new treaty will replace the existing treaty, which was entered into in1971.
  • Gordon Brown, Chancellor of the Exchequer, has made it clear in speeches and newspaper articles that the UK will resist proposals to harmonize direct tax regimes across the EU. The UK will also resist any attempt to introduce majority voting on tax issues, insisting on retaining its veto.
  • Spain only needs minor changes in its tax law to carry out Directives on taxation of savings income (2003/48/EC) and of interest and royalty payments (2003/49/EC).
  • The UK will introduce a domestic transfer pricing regime on April 1 2004. Groups of companies face a huge compliance burden in documenting and justifying asset transfers within the UK. Companies will have a further consultation period until February 10 2004 to respond to the plan, which were confirmed in the pre-Budget report on December 10 2003.
  • In late October 2003, Germany's highest tax court (the Bundesfinanzhof or Federal Tax Court) released a judgment holding that corporate net operating losses (NOL) continue to be deductible following indirect changes in the ownership of the loss corporation (judgment of August 20 2003 - IR 61/03). For prior discussion of the case and related NOL disallowance issues, see the article by Prinz zu Hohenlohe and Gruendig in International Tax Review (May 2003, page 25).
  • Sed Crest reveals what kind of picture the survey of tax services in Latin America draws and presents the challenges for tax directors and warnings for tax advisers
  • On October 31 2003 the Brazilian government issued Provisional Measure (PM) 135/2003, promoting changes to the COFINS tax regulations.
  • Argentina has recently launched new thin-capitalization rules by reforming the Income Tax Law, effective October 22 2003.
  • Vispi T Patel of Deloitte Haskins & Sells explains how expatriates are taxed after a key decision and legislative change