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With only nine months to go before the EU expands to 25 members, Peter Cussons and Chloe Sylvester of PricewaterhouseCoopers analyze the tax and legal issues surrounding EU accession

On June 11 2003 the Ministry of Finance in Japan and the Treasury Department in the US announced that Japan and the US have reached an agreement in principle on the text of a new tax treaty between Japan and the US. The proposed new treaty will make an overall revision of the treaty between the two countries, which was put in place in 1971. The new treaty, while taking the OECD model treaty as a basis, will reflect the importance of the economic relationship between the two countries as strategic partners, promote investments between them, and at the same time will prevent improper exploitation of the treaty.

The newly elected national government announced few weeks ago a reform package, now before Congress, intended mainly to combat tax evasion. Among other unveiled initiatives, the executive has made public its intention to reinforce the punitive legislation on tax crimes and submitted amendments to the income tax.

Blake Dawson Waldron hired Geoff Mann, former head of tax at Freehills, on August 19 2003. Mann will be working with clients on GST, stamp duty, land tax and employee benefits tax from the firm's Melbourne office.

The London office of US-firm Hogan & Hartson has expanded to include a tax practice, headed by former McDermott, Will & Emery tax partner Jonathan Ivinson. The practice will be advising on the tax aspects of mergers and acquisitions, fund work and dispute resolution.

The Italian government has published a draft of the proposed new law on corporate taxation, which it expects will come into force on January 1 2004. The wide-ranging tax reforms include reducing the corporate income tax rate from 36% to 33% and new participation exemptions.

Yell Group completed a listing on the London stock exchange with a $3.2 billion initial public offering in July 2003. Sarah Priestly, a tax partner at Weil, Gotshal and Manges in London, advised Yell Group. "The complicated deal was structured so that the US investors were not faced with tax problems," she said.

The Russian Ministry of Taxes and Levies published an order on the registration of foreign organizations with the tax authorities on July 28 2003. Changes to the way multinational companies are registered with tax authorities in Russia will take effect from October 1 2003.

The UK Customs & Excise unique amnesty scheme closes on September 30 2003. The scheme allows businesses trading above the VAT threshold but not registered for VAT to register without incurring a penalty for late notification.