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In March 2004 the European Court of Justice (ECJ) invalidated a French statute that taxed the unrealized appreciation inherent in corporate stock held by long-term French resident individuals upon transfer of their tax residence from France to another country (Hughes de Lasteyrie du Saillant - Case C-9/02).

Advocate General Kokott issued her non-binding opinion in the Manninen case (C-319/02) on March 18 2004 regarding the compatibility of the Finnish tax credit system with the EC Treaty. In Finland, economic double taxation of corporate profits is avoided by crediting corporate income tax paid by the company against the income tax payable by the individual on the dividend received. The credit is denied, however, if the company distributing the dividend is not a resident of Finland.

EU member states should consider a common policy on tax rates and reliefs. It may help them deal with treaty issues raised by the European Court of Justice, argue Timothy Jarvis, Jens-Uwe Hinder and Dirk Koehler of Hammonds

The first three multilateral advance pricing agreements have been concluded in Europe. Similar agreements are likely to grow in popularity, according to Dave Rutges, Eduard Sporken, Dirk Van Stappen and Pascal Luquet of KPMG

The Israeli Ministry of Finance's plan to cut the country's corporate tax rate from 36% to 30% government will occur over four years and introduce investment incentives for both foreign and domestic companies. The existing investment incentive regime will be replaced with three new regimes to encourage investment in specific regions and sectors of the economy.

Television coverage of the Olympic Games in Athens could be limited outside the EU if Greece refuses to refund value-added tax (VAT) paid by broadcasters. Greece has only guaranteed VAT refunds for television broadcasting companies with registered affiliates in the EU. The European Broadcasting Union said in a statement that Asian broadcasters would be hit hardest.

Mark Penney, a tax partner at rival big-four firm Ernst & Young, joined KPMG in London on May 7 2004 to head-up the firm's international tax group. Penney specializes in cross-border mergers and acquisitions and advised on Walmart's acquisition of Asda and Scottish Power's purchase of PacifiCorp.

Although Irish tax law imposes an obligation on companies generally, and on others who pay interest to persons whose usual place of abode is outside Ireland, to withhold tax from certain payments of interest, there are extensive carve-outs from this withholding obligation in the case of outbound interest payments. Among these carve-outs, sections 246(3)(ccc) and (h) of the Taxes Consolidation Act 1997 (TCA) provide that withholding tax is not to be deducted from certain interest payments where the recipient of the interest is, by virtue of the law of a relevant territory, resident for the purposes of tax in the relevant territory. A relevant territory means a member state of the European Community (other than Ireland) or a territory with which Ireland has a double taxation treaty, for example, the US.

by Richard Collier-Keywood, UK head of tax, PricewaterhouseCoopers