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EU finance ministers agreed on June 2 2003 a tax package aimed at securing tax revenues and freeing up intra-group payments within the EU. The tax package includes:

On May 30 2003 Law 10,684 introducing modifications to the tax instalment programme for Brazilian taxpayers was enacted. The general rules set forth in Law 10,684 can be summarized as follows.

Philippe Hinnekens of Allen & Overy uncovers the detail behind the challenge to hybrid entities in cross-border tax planning

In the June 2003 issue of International Tax Review, as part of the European survey of leading tax advisers, on page 19, PricewaterhouseCoopers, overall winners in the Swiss table of results, appeared as "Landwell (PricewaterhouseCoopers)" and "Landwell" whereas the they should have been listed as "PricewaterhouseCoopers". We apologise for this error.

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

David Evans, Robert Hodges and Ben Kiekebeld of Ernst & Young analyze the case and what it means for cross-border loss relief across Europe

On June 10 2003 the governments of the US and Japan agreed on a Treaty to eliminate taxes on some transactions between the two countries. The Treaty ends withholding taxes imposed on certain dividends, interest payments and royalties. The agreement will replace the existing Treaty, which has been in place for nearly 30 years and subjects companies to double international taxation. The two governments expect to sign the treaty in July 2003 prior to formal ratification.

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.

Holly Glenn, a former transfer pricing specialist at PricewaterhouseCoopers, joined Baker & McKenzie as a senior economist on July 1 2003. She will provide economic and valuation services in connection with transfer pricing projects and other tax matters.

The official protocol of March 12 2002 amending the Swiss-German Double-Tax Treaty entered into force on March 24 2003. The following changes apply.