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Multinationals doing business in Italy have been confused by recent Supreme Court decisions on permanent establishments, including the Philip Morris case. Piergiorgio Valente and Gianpaolo Valente of Studio Legale Tributario GEB Partners focus new light on blurry concepts

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Orrick Herrington & Sutcliffe has opened an office in Milan with 23 lawyers from Ernst & Young's 280-lawyer Italian legal arm, Studio Legale Tributario. The former national director of legal services and anti-trust and regulatory law at Studio Legal Tributario, Alessandro De Nicola, will lead the Milan office. Clients of the lawyers include Italian power company ENEL, Vivendi, Universal Music Italy and Italian insurance company RAS Italia.

For many years the Brazilian government has failed to enact fiscal reforms and to revise its inefficient indirect tax system, which imposes several types of taxes collected by the federal, state and local governments. Over the last decade this situation has developed into a serious tax competition between the different layers of the Brazilian government. The current tax system is characterized as a maze of complicated tax rules, which greatly increase the cost of products and services in the country. The result has been that Brazilian taxpayers are among those with the highest tax burden, representing 36.45% of the country's gross domestic product (only below Sweden - 47% and Germany - 36.7%).

The High Court has overturned the Inland Revenue's position on the tax treatment of share buy-backs. Ian Bowler and Mike Hardwick of Linklaters reveal the implications of the decision

Proposed rules on preferred shares have a lot to offer foreign credit institutions in Spain. Carlos Albiñana of Allen & Overy shows where and how

Biotech company ImClone has delayed announcing its financial results and may be forced to restate its earnings from 2001 onwards to cover the unpaid taxes of its former chief executive.

The European Venture Capital Association (EVCA) has said that differences in national tax and legal regimes across Europe are hampering the development of Europe's private equity and venture capital sector.

Watson, Farley & Williams has hired a senior associate from Allen & Overy for its New York tax group. Patricia Iandoli has joined the firm's international tax group as a partner. Iandoli specializes in asset finance tax work.

PricewaterhouseCoopers has hired Lindy Paull, the former chief of staff of the Congressional Joint Committee on Taxation as co-managing partner of its Washington national tax services practice. Paull joined the firm on May 1 2003 and will work with co-leader Robert Morris. Paull spent 17 years working in Congress, and before working at the Joint Committee on Taxation held positions with the Republican staff of the Senate Finance Committee.