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The Sarbanes Oxley Act introduced in August last year in the US, has forced a number of tax specialists to leave the large accounting firms. New firms specializing in different areas of tax, particularly tax valuations and transfer pricing, are competing in an increasingly fluid market place in Europe and the US.

Larry Langdon, former commissioner of the large and mid-size business division at the IRS in the US, has joined Mayer, Brown, Rowe & Maw. Langdon will be a partner and director of the firm's global tax practice based in the Palo Alto office.

Foreign corporations with subsidiaries subject to income tax in the United States have likely implemented or are likely familiar with a popular state income tax planning strategy known as the passive investment company, or PIC. Due to a recent trend in state legislation, the efficacy of certain PIC planning is at least somewhat in jeopardy.

Larry Magid: The ATO is trying to encourage voluntary compliance Corporate taxpayers face increasing scrutiny from the Australian Taxation Office (ATO). The ATO's Cooperative Compliance Model encourages companies to actively engage with the ATO to ensure taxation compliance while also outlining the procedures the ATO will use and the penalties it can enforce.

KIM & CHANG

PKF is an international association of specialist tax, accounting and business consulting firms, advising clients in diverse industry sectors, through a network of 240 member firms in 114 countries. The PKF Australian Tax Practices have highly trained tax consulting teams with expertise in all areas of corporate and personal taxation, with particular specialist skills in corporate restructures, tax audit management, international tax, expatriate taxes, Captial Gains Tax, Goods and Services Tax and research and development concessions.

The German government approved on August 13 2003 a draft tax Bill that contains, among other measures, a completely redesigned set of thin-capitalization rules that are intended to be compatible with European law. The European Court of Justice (ECJ) held in its December 2002 Lankhorst-Hohorst decision that the existing thin-capitalization rules violate EU law. The ECJ's primary objection to the existing rules is that they apply primarily to foreign shareholders of German corporations, placing foreign EU shareholders at a disadvantage compared with similarly-situated, German-resident shareholders. While the German government was expected to respond to Lankhorst-Hohorst by extending the thin-capitalization rules to domestic shareholders (and their related parties), many tax professionals were nonetheless astonished by the sweep of the new proposal.

Tax adjustments relating to the remuneration of inter-company administrative, technical and commercial support services are as frequent as the performance of such services is common.

UK plans to extend transfer pricing and thin-capitalization rules to domestic transactions

Heather Meeker of Tomlinson Zisko considers tax strategies for hi-tech firms with high-value intellectual property