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On May 3 2002, rulings were given in two important plenary cases concerning Norway's penalty tax. The court found that the use of enhanced additional tax (45% or 60% of the assessed tax), and at the same time punishment imposed under the Norwegian criminal law, was a breach of Protocol 7, article 4 of the European Convention on Human Rights (ECHR), and the rules governing double penalty. In one case, the additional tax was imposed before the court sentence was delivered in the criminal case. In the other case the two punitive decisions were applied in reverse order.

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Freshfields Bruckhaus Deringer has lost its head of Dutch tax to a local firm. Charles Langereis joined Spigthoff on July 1 and will lead the firm's tax practice. Before working at Freshfields Bruckhaus Deringer he headed the tax group at Stibbe. He brought over one associate and many of his clients.

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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