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Andrea Silvestri: Law firms handle high-end tax transactions Two Italian law firms have significantly expanded their tax practices to plug a perceived gap in the market for international tax services. Studio Legale Sutti opened a new tax office in Milan while Bonelli Erede Pappalardo poached international tax specialist Andrea Silvestri from Deloitte & Touche in Boston to lead their newly-formed tax group.

Three months after the landmark signing of the Closer Economic Partnership Arrangement (CEPA) between Hong Kong and China, the two governments have signed six annexes further clarifying the terms of the arrangement. The arrangement covers three broad areas - trade in goods, trade in services, and trade and investment facilitation. For trade in goods, from January 1 2004 the CEPA permits exports of Hong Kong origin from 273 tariff classes to enjoy zero tariffs, as long as they meet CEPA rules-of-origin requirements. Included in the 270 classes are electrical and electronic products, textiles and clothing, jewelry and cosmetics. China has also agreed to apply a zero import tariff upon applications by local manufacturers for other tariff classes maintained in China's tariff system that meet the CEPA rules of origin. It will do this by January 1 2006 at the latest.

Belgian taxpayers could receive a tax amnesty to regularize their undeclared offshore savings. Marc Quaghebeur of Vandendijk & Partners reveals how

European Tax Commissioner Frits Bolkstein issued a warning to member states over corporate tax policies at an EU conference on tax reform on December 5 and 6 2003. National corporate tax policies face challenges from the European Court of Justice over cross-border investment in Europe.

The Hong Kong SAR government is making agreements to avoid double taxation on income from international transportation operations with other countries and is developing Hong Kong as an international logistic centre. The latest agreement, on shipping operations, was signed with Norway in October 2003. It was the fifth of its kind and the second this year. Another was made with Germany earlier this year.

The fourth draft of the foreign investment entity legislation (FIE legislation) was released by the Canadian Department of Finance on October 30 2003 and generally adheres to the structure of earlier drafts. Certain major changes, and a host of technical revisions, have been adopted. The FIE legislation is to be effective for taxation years beginning after 2002.

In November 2003 the European Commission issued its latest comprehensive monitoring report on the state of preparedness for EU membership. Most acceding countries should have no particular difficulty in meeting the taxation requirements upon accession on May 1 2004, but the European Commission requires enhanced efforts on the part of Estonia, Malta and Slovenia to meet their obligations as far as direct taxation in general is concerned.

The draft Finance Bill for 2004 provides for the carry forward of tax losses without any time limit. Accordingly, the distinction between ordinary losses, which can be carried forward for five years, and deemed deferred depreciation allowances, which can be carried forward with no time limit, will most likely no longer exist.

Ernst & Young's Philip Anderson and Robert Miall reveal the findings from the firm's global transfer pricing survey revealing which firms are most at risk

Dividends from qualified foreign corporations received by US non-corporate shareholders will benefit from maximum reduced income tax rate of 15%. Oscar Teunissen, Oren Penn, Steve Nauheim and Puneet Arora of PricewaterhouseCoopers explain how it works