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The Spanish framework for research and development (R&D) and innovation activities has traditionally been extremely advantageous, especially with regard to tax incentives, advantages which have been enhanced by a recent reform.

International consulting firm LECG has hired a group of former Andersen staff to develop a European transfer pricing group in London. Former Andersen international tax partner Richard Fletcher is leading the group and has joined as a director. Senior economist Stephanie Pantelidaki and senior associate Darren Andrews joined the firm earlier this month. Both Pantelidaki and Andrews initially joined Deloitte & Touche when it merged with Andersen. Another ex-Andersen partner Nicholas Woolf is also working with the group as a consultant.

Jeffrey Friedman and Glenn Walsh of KPMG analyze efforts to streamline US sales and use taxes in the face of projected Budget deficits

PricewaterhouseCoopers' tax and legal specialists help clients gain business advantage by providing multi-disciplinary and innovative solutions to their complex business issues.

ZINI & ASSOCIATES is an international law firm providing multidisciplinary services including legal and tax advice with a continued focus on sophisticated areas of the law, such as national and cross-border M&A, Capital Markets, Structured Finance, Banking, Business and Corporate Law, Telecommunications, Information Technology, E-Commerce, Antitrust and EU Law, Intellectual Property, Industrial and Commercial Real Estate, Entertainment, Arts, and Sports.

Todd M Landau of PricewaterhouseCoopers investigates permanent establishment challenges to related party cost-plus service arrangements

The Brazilian Central Bank issued on April 16 2003 Circular 3187 modifying articles 9 and 10 of Circular 2677/96. The latter relates to non-resident accounts maintained in reais (local currency) with a Brazilian financial institution (commonly referred to as CC5 accounts) and international transfer of reais. The CC5 accounts allow individuals and companies to undertake international transfer of reais to bring funds to Brazil or send them abroad. Such accounts are ordinarily used for payments of dividends, capital increase/reduction, inter-company loan arrangements and Brazilian investment abroad.

Zurich, Switzerland

Since the Finance Act 1999, taxpayers who have been residents of France for tax purposes for at least six years within the last ten years are taxable on the latent capital gains derived from participations of 25% or more that are held directly or through family members, on transferring their residence outside France. This exit tax, which is codified under section 167 of the French Tax Code, is intended, in particular, to deter taxpayers from changing residence prior to the sale of a business.

The State Administration of Taxation (SAT) recently standardized the tax treatment of representative offices, effective from July 1 2003. The circular clarifies that tax treatment shall be based on the activities carried out by the head office: