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Following the publication of Normative Instruction 167 (June 18 2002), the Brazilian tax authorities issued, on October 1 2002, Normative Instruction 200 (NI 200), which brings further details and clarification about the new requirements for legal foreign entity domiciled outside Brazil to obtain a taxpayer identification number. Under NI 200, non-resident companies owning goods and rights in Brazil, subject to public registration, are obliged to apply for and obtain a federal taxpayer identification number. This is known as the Cadastro Nacional da Pessoa Jurídica (CNPJ).

New corporate restructuring rules mean companies need to look carefully at how they use losses and those of potential acquisition targets. For the nimble, Marcellin N Mbwa-Mboma, of Baker & McKenzie in New York, says the advantages can be significant

The IRS has issued its final QI audit guidelines. Now the first QI audit is approaching. It will be a landmark for financial institutions and auditors and will test the practicality and efficiency of the QI withholding system. Chip K Collins, KPMG, Washington DC, and Hans-Dieter Wolf, KPMG, Düsseldorf report

Ernst & Young failed to suspend a disciplinary investigation into its audit of insurance company Equitable Life. The High Court overruled Ernst & Young's claim that an inquiry would compromise its position in civil proceedings brought against it by Equitable. Ernst & Young has staunchly defended its 1999 audit of Equitable that led to the company suing the professional services firm as well as company directors on behalf of its policy holders.

Pamela Olson has been sworn-in as US treasury assistant for tax policy. Treasury secretary Paul O'Neill swore-in Olson on September 26 this year. Olson has supervisory responsibility for providing the treasury secretary with policy analysis, advice and recommendations relating to all aspects of domestic and international issues of federal taxation including legislative proposals, regulatory guidance and tax treaties. She will also deal with official estimates of government receipts for the president's budget, fiscal policy decisions and treasury cash management decisions.

Marc de Bruijn: wanted the challenge of leading a group SchutGrosheide, the Dutch law firm and member of UK firm DLA's European alliance, D&P, has boosted its tax department with the appointment of three tax specialists.

The European Court of Justice (ECJ) Advocates General (AG) recently concluded in two separate cases that certain Dutch corporate income tax rules and the German thin capitalization rules conflict with the freedom of establishment principle in article 43 of the EC treaty.

During the last week of September, two prosecution cases on tax evasion were heard in the courts. It is rare that the Hong Kong Inland Revenue Department (IRD) brings two cases almost simultaneously to the court for prosecution.

A High Court decision raises doubt over AOL's relief from VAT in the UK, which the internet service provider (ISP) received in March from the Customs & Excise Commission. The March decision exempts non-European ISPs from VAT in the UK, providing they mainly supply content, not telecommunications. Freeserve estimates that Treasury has lost £100 million ($157 million) as a result and plans to continue its campaign against what it sees as unfair competition.

Attracting delegates from over 50 multinationals and 24 countries, Paris’ Opera district was brimming with a very select group of tourists in late September when International Tax Review, together with sponsors KPMG, held its second annual transfer pricing forum. Georgina Stanley reports on the action