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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.

UK-resident companies now have a clear right to deduct upfront the professional fees associated with preparing an abortive bid for another company (UK or non-UK resident). This is the effect of the High Court decision in Camas plc v Atkinson, published in July. Any resulting tax losses which cannot immediately be used by the company itself can be set against taxable profits elsewhere in the company's group or carried forward.

KPMG is the global network of professional services firms, whose aim is to turn understanding of information, industries and business trends into value. With nearly 100,000 people worldwide, KPMG member firms provide assurance, tax and legal and financial advisory services from more than 750 cities in 150 countries.

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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.

Richard J Vann of Greenwoods & Freehills shows where the tax opportunities lurk under the latest US-Australia double tax agreement

On June 11 2003 the Ministry of Finance in Japan and the Treasury Department in the US announced that Japan and the US have reached an agreement in principle on the text of a new tax treaty between Japan and the US. The proposed new treaty will make an overall revision of the treaty between the two countries, which was put in place in 1971. The new treaty, while taking the OECD model treaty as a basis, will reflect the importance of the economic relationship between the two countries as strategic partners, promote investments between them, and at the same time will prevent improper exploitation of the treaty.

On July 9 2003 the Brazilian Congress approved a Bill, originally from 1989, relating to the application of the municipal services tax (ISS). The Bill brought important changes to the existing legislation and expanded the original list of services subject to the tax. The newly-added services are mainly relating to IT and banking services. The new project is expected to increase the total of ISS collected by municipalities from R$8 billion ($2.7 billion) to R$15 billion ($5 billion) within the next three years.

By Chee Weng Lee, PricewaterhouseCoopers in Hong Kong

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