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ZINI & ASSOCIATES is an international law firm providing multidisciplinary services including legal and tax advice with a continued focus on sophisticated areas of the law, such as national and cross-border M&A, Capital Markets, Structured Finance, Banking, Business and Corporate Law, Telecommunications, Information Technology, E-Commerce, Antitrust and EU Law, Intellectual Property, Industrial and Commercial Real Estate, Entertainment, Arts, and Sports.

Todd M Landau of PricewaterhouseCoopers investigates permanent establishment challenges to related party cost-plus service arrangements

The Brazilian Central Bank issued on April 16 2003 Circular 3187 modifying articles 9 and 10 of Circular 2677/96. The latter relates to non-resident accounts maintained in reais (local currency) with a Brazilian financial institution (commonly referred to as CC5 accounts) and international transfer of reais. The CC5 accounts allow individuals and companies to undertake international transfer of reais to bring funds to Brazil or send them abroad. Such accounts are ordinarily used for payments of dividends, capital increase/reduction, inter-company loan arrangements and Brazilian investment abroad.

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Since the Finance Act 1999, taxpayers who have been residents of France for tax purposes for at least six years within the last ten years are taxable on the latent capital gains derived from participations of 25% or more that are held directly or through family members, on transferring their residence outside France. This exit tax, which is codified under section 167 of the French Tax Code, is intended, in particular, to deter taxpayers from changing residence prior to the sale of a business.

The State Administration of Taxation (SAT) recently standardized the tax treatment of representative offices, effective from July 1 2003. The circular clarifies that tax treatment shall be based on the activities carried out by the head office:

The World Trade Organization granted the EU permission to apply sanctions worth $4 billion against the US in the ongoing Foreign Sales Corporation case on May 7. The EU wants the US to ensure compliance with the WTO rules before the beginning of next year and will review the US' progress in autumn this year. The most popular bill in the US to deal with the export subsidies is the Crane Rangel Bill which suggests replacing the FSC benefit with tax benefits for companies producing their good in the US rather than overseas.

Vanuatu has been removed from the OECD's list of uncooperative tax havens after the country committed to improving the transparency of its tax and regulatory systems and to establishing effective exchange of information for tax matters with OECD countries by the end of 2005. The list was published in April 2002 and the Vanuatu is the first to be removed. Six jurisdictions remain on the list.

Internet service provider AOL is expanding its Luxembourg operations to reduce its value-added tax (VAT) liability. The move comes in anticipation of the EU's Taxation of Digital Sales Directive, which comes into effect on July 1 this year and means that the company will have to start charging customers VAT on digital downloads.

Basic International Taxation - gives insights into some of the nooks and crannies of international tax The author's preface declares Basic International Taxation to be a clarification of the basic principles of international taxation, and it succeeds very well. There are numerous books that look at subjects within the field of international taxation, but what Roy Rohatgi has produced is a work that spans the entire subject and places the various elements in context. For those who are looking for basic understanding, perhaps as a prelude to more in-depth analysis or as occasional practitioners of international tax, Basic International Taxation will be a useful addition to the bookshelf.