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Sean Foley Alexey Manasuev On the final day of 2008, the US Treasury department and the IRS issued temporary regulations addressing cost sharing arrangements (CSAs) between controlled taxpayers.

An income tax amendment regarding an extension of the loss carryforward period passed the 3rd hearing in the Legislative Yuan on January 6 2009. The carryforward period has now been extended from five to ten years.

Álvaro de la Cueva Unlike most of its OECD counterparts, Spain has traditionally considered that most payments for software fall under the category of royalties. As such, Spain inserted an observation in paragraphs 14, 15, 17.1 and 17.4 of the commentaries on article 12 of the OECD Model Tax Convention reserving its right to charge tax in cases where less than full rights were transferred and the payments were for the commercial exploitation of the software, or for the business use of not-absolutely-standardised software.

In recent years, companies and individuals started benefiting from the speed of the modern tax system to increase competitiveness. A huge revolution began in the last eight years resulting from the enforcement of several tax legislative improvements.

Suzanne Boers The tax treaty between the Netherlands and Mexico has been amended after the two countries signed an amending protocol on December 11 2008. The protocol needs to go through the legal authorisation procedures in both countries and is expected to come into effect on January 1 2010.

Henry An David Jin-Young Lee On September 1 2008, the ministry of strategy and finance announced various proposed amendments to tax laws which include provisions to provide penalty relief to taxpayers maintaining contemporaneous transfer pricing documentation.

Michael Honiball has moved from KPMG to Webber Wentzel in Johannesburg in South Africa. He will continue to specialise in international corporate tax, transfer pricing and the taxation of trusts and high net wealth individuals.

Five lawyers have become tax partners at DLA Piper. Jeroen Gobbin in Antwerp, Uwe Eppler in Hamburg, Jeffrey Korenblatt in Washington, DC. Paul Rutherford in London and Trina Oettinger in East Palo Alto are the new members of the partnership.

Twenty partners will make up the tax practice of a new Italian law firm following the merger of Camozzi & Bonissoni Varrenti & Associati and Studio Associato LCA.

US law firm Thompson Hine has elected Gregory Gawlik as a partner in the tax practice of the firm's Cleveland office.