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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.

Anthony Davis, a former senior adviser at the UK Inland Revenue, has joined Cadwalader, Wickersham & Taft as special counsel in London. The move represents a new beginning for the firm in providing tax advice from the UK. Davis will advise on tax issues within a broad range of securitization, restructuring and insolvency matters both in the UK and Europe. The ex-Ernst & Young and Lovells partner comes from an unprecedented position at the UK Inland Revenue where he was employed to give an external perspective to business tax policy.

John Whiting: Clients may face more intrusive questions Mark Lee: Accountants want to ensure that the new regulations are workable New legislation on tax offences will hit UK tax practitioners this autumn. Directive 2001/97/EC of the European Parliament requires all member states to pass national legislation to prevent the use of the financial system for the purposes of money laundering and tax evasion. In the UK implementing legislation, financial gains from tax-related offences is treated the same as proceeds from money laundering, drug trafficking or theft.

The French government announced on June 27 2003 that it would be offering tax breaks for foreign executives working in the country. The tax breaks, which would also apply to returning French nationals, aim to simplify procedures for foreign investment. The government hopes to influence creativity within the country's high-value service sectors.

Stephen Coleclough of PricewaterhouseCoopers analyzes value-added tax and its future in Europe

The new rules below can be applied to the investment on or after January 1 2003, but from the years ending on or after April 1 2003. If a corporation, whose business yearend is March, acquires the eligible asset during the period from January 1 to March 31 2003, it can enjoy the tax benefits in the year beginning April 1 2003.

The January 2003 issue of International Tax Review reported on the landmark Lankhorst-Hohorst decision of the European Court of Justice (ECJ Case C324/00 of December 12 2002) by which the court held a central provision of the German thin-capitalization rules to contravene EU law.

David Benson and Michael Mundaca of Ernst & Young deliver an update on President Bush's tax-cut package and outline the implications of the new US-Japan tax treaty

Dr Jürgen Hartmann of CMS Hasche Sigle reveals the implications of new rules on the reduction of tax benefits and the exemption provisions