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Under the Austrian participation exemption dividends received by an Austrian resident corporate shareholder from a domestic company are tax exempt irrespective of the percentage of the participation and of the holding period. In contrast, dividends from a foreign company are only tax exempt if the shareholder holds at least 10% in the share capital of a foreign company eligible for such exemption and if such participation is being held continuously for at least one year.

Michel Guilluy, Eric Centi and Vincent Marquis of PricewaterhouseCoopers, examines the interaction between the MFN clause and the fundamental freedoms in the EC Treaty

In May leading international tax practitioners from around Europe gathered in London for the presentation of the first International Tax Review European Tax Awards. Our cameras were there

NBC IAC/Interactive, an internet company, has sold its stake in Vivendi Universal Entertainment (VUE) to NBC Universal for $3.4 billion, ending a $620 million dispute over taxes on IAC's preferred stock in VUE.

The EU's long-awaited Savings Tax Directive and the separate savings tax agreements with five other European countries, designed to combat tax fraud and increase cooperation on tax matters between EU countries, came into effect on July 1.

Corporate tax directors in the US are weighing up the possibilities for repatriating foreign earnings after the Internal Revenue Service (IRS) issued its latest round of guidance on a Jobs Act 2004 provision that allows companies to bring funds back to the US at a reduced rate of tax.

On July 1 the Philippines Supreme Court announced a temporary freeze on the implementation of the expanded law on value-added tax. The controversial law had caused a rise in fuel prices, which led to petroleum retailers and the airline industry lobbying officials in Manila. The court took note of these efforts, voting 13-2 in favour of a temporary freeze. Hearings on the tax law, which was at the core of President Gloria Macapagal Arroyo's strategy for fiscal stability, will begin on July 26.

Philip Baker, QC, of Gray's Inn Tax Chambers in London, considers the pros and cons

Just as this issue was going to press on July 5, the ECJ released its decision in the eagerly-awaited D case (C-376/03) concerning Dutch net wealth tax and the free movement of capital under the EC Treaty. The court ruled that the treaty does not prevent a member state from denying a non-resident who has most of their wealth in the country where they live the allowances that they grant its own residents. The court also decided that the benefits of a tax treaty between two member states do not have to be extended to a third EU member.

Haarmann Hemmelrath has bolstered its international tax practice by hiring a new partner in Paris. Jacques-Henri de Bourmont, a French corporate and international tax adviser who is also qualified in Germany, joined the firm from EY Law on June 15.