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Sixth VAT Directive – Article 21(1)(c) – Persons liable to tax – Person mentioning the tax on an invoice – Tax paid in error by a non-taxable person and included in the invoice established by that person.

Removal from the register.

VAT – Article 13A(1)(b) and (c) of the Sixth Directive 77/388/EEC – Exemption – Psychotherapeutic treatment given in an out-patient facility provided by a foundation governed by private law (charitable establishment) employing qualified psychologists who are not doctors – Direct effect.

The International Primary Market Association (IPMA) has released standard tax exemption clauses to take into account the new EU Savings Directive.

Much attention has been focused on the issuance of new regulations such as the final regulations regarding stock-based compensation and proposed new regulations governing services. But there has been no lack of development in the IRS's advance-pricing agreement (APA) programme.

On September 2003 the Mexican Congress approved the Mexico - Australia Tax Treaty (the Tax Treaty).

Ireland now has double taxation agreements (DTAs) with 41 countries. A complete list of these DTAs can be seen at www.mop.ie.

Gerald Kafka and Rita Cavanagh joined Latham & Watkins' tax controversy practice in Washington DC on September 9 2003. Both partners left McKee Nelson to make the move and will concentrate on tax controversy litigation.

Carol Dunahoo, formerly director, International and the US Competent Authority within the large and mid-size business division at the IRS, has moved to Baker & McKenzie in Washington. The move was announced on October 13 2003.

The Treasury recently finalized an amendment to its regulations on qualified cost-sharing arrangements (QCSAs) requiring that the deemed cost of stock options and other stock-based compensation be treated as a development cost to be shared with the participants of a QCSA along with the cash-based compensation of the employees involved in the development of intangibles subject to the arrangement. In many cases the effect will be to require greater cost contributions by the foreign participants in QCSAs and an increase in taxable income to the US participants. Taxpayers have rarely treated any part of the cost of stock options as a cost to be shared under a QCSA and have vociferously objected to the new rules.