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Maria Eugenia Palombo of Klegal reviews the key transfer pricing cases in Italy and reveals the implications of the decisions

A number of countries have stepped up efforts to expand their double-taxation agreement networks. The Russian government has agreed double-taxation treaties with Syria, New Zealand and Iceland. The treaties were ratified by the Duma on June 4. Belgium and France are working to update a double-tax treaty that dates back to 1964. The UK government expects to complete work on agreements with Australia, Chile, Croatia, France and Slovenia before the end of March 2004.

PricewaterhouseCoopers' Japanese practice has lost Makoto Nomoto to KPMG. He will be responsible for providing corporate tax services to Japanese clients in Northeast Asia from the New York office.

Low Hwee Chua and Wong Chee Ming of Deloitte & Touche scrutinize the foreign-source income exemption guidance released by the Singapore tax authorities

The timeframe in which non-residents could request the refund of taxes paid or withheld in excess has traditionally generated significant litigation. In 1997 this timeframe was set in two years unless provided otherwise in the ministerial order implementing the corresponding tax treaty (very few of the Spanish tax treaties are implemented by ministerial orders). This time frame differed from that applicable to tax residents. The latter could request tax refunds within the general tax statute of limitations period (five years through 1998 - four years afterwards). The Ministry of Finance could extend the two-year period to five or four years (before and after 1998) if reciprocity existed in the other country involved.

Dick Kocak, former chief of the excise tax branch at the IRS, has moved to KPMG to lead their excise tax practice in Washington. Ruth Hoffman, a former senior technician in the same office at the IRS, followed Kocak to KPMG. Between them they were responsible for the IRS's published guidance on excise taxes and have nearly 45 years of IRS experience.

Stéphane Chaouat, a former partner at Cleary, Gottlieb, Steen & Hamilton, has joined the tax practice of Weil, Gotshal & Manges in Paris. Jean-Charles Béroard will join him as senior associate after leaving Jones Day.

Lawrence Kemm joined McDermott, Will & Emery in the UK from Baker & McKenzie on June 16 2003. Kemm is confident that McDermott, Will & Emery's relationship with other firms around the world will allow him to continue providing high quality tax advice internationally.

Michael Weaver and Travis Taylor, formerly in PricewaterhouseCoopers's tax valuations department, have set up Gravitas Partners in the UK with two former colleagues from the big-four firm. The practice hopes to provide a more personal service to its clients (some of whom have followed Taylor and Weaver from PricewaterhouseCoopers), while also providing access to senior tax practitioners with experience in a big-four firm.

Eric Roose: Avoiding high local taxation is important for offshore funds White & Case has launched a Tokyo investment and hedge-fund desk with its associated firm Kandabashi Law. The new eight-strong group delivers advice to offshore fund managers regarding tax-efficient hedge-fund structuring. Chris Wells, executive partner of White & Case in Tokyo, leads the group. Eric Roose and Yoshiaki Uno are also partners working on the project.