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On July 12, the IRS released revenue procedure 2002-52, updating the procedures for requests for competent authority assistance. Revenue procedure 2002-52 supersedes revenue procedures 96-13 and 96-14, the prior IRS guidance on this subject.

Multinational companies may be able to set up a single, pan-European pension scheme for employees if a European lobby group is successful in its battle to remove tax obstacles. The group backing the move is pan-European pensions group (PEPGO), an association of 20 multinationals including Swiss Life and Kvaerner. Business and information technology consultants AMS Management Systems is making an application to the UK Inland Revenue to place one of its UK employees in its Netherlands company pension scheme. Being unable to establish a single scheme can cost multinationals with employees throughout the EU millions of dollars each year as they are left unable to pool either investments or administrative costs. But on account EU tax legislation is almost impossible to pass because of the unanimity requirement resulting from member states' concerns about losing revenue, the EU pensions directive signed earlier this year does not cover tax issues. AMS, at the suggestion of PEPGO, is therefore trying another tactic.

New regulations from the US Treasury recharacterize non-deductible dividend payments to foreign parents. By Mike Danilack, Diane Renfroe and Lisa Askenazy Felix, Deloitte & Touche, Washington, DC

With VAT fraud in the EU taking on forms never envisaged by the original legislators, concerted action to tackle the issue is urgently required. By Stephen Dale and Hélène Percie du Sert, Landwell – the correspondent law firm of PricewaterhouseCoopers, Paris, and Christine Sonneleitner, PricewaterhouseCoopers, Vienna

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International Tax Services

Ernest Mazansky, (standing) and team, Werksmans South African law firm Werksmans has boosted its tax group with three lateral hires including the former national chairman of Grant Thornton Kessel Feinstein in South Africa.

Sed Crest speaks to the leading tax advisers in North America at a time when creative tax advice is under increasing threat from the media, lawmakers and the IRS