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The ECJ has held that Swedish tax law relating to the taxation of certain share transfers is illegal under EC law.

A recent notice, effective from January 1 2003, clarifies the approval, registration, foreign exchange and taxation of foreign investment enterprises (FIEs) with less than 25% foreign ownership. The notice unifies the approval, registration and foreign exchange treatment of all FIEs in China by requiring FIEs with less than 25% foreign ownership to obtain MOFTEC approval and abide by the same registration and foreign exchange procedures as other FIEs. However, the notice states that FIEs with less than 25% foreign ownership will not be entitled to the preferential tax policies offered to other FIEs, including the duty-free import of capital equipment.

R&D tax credits, cost-sharing technology development agreements and capitalizing expenses for intangibles are all factors that should be part of an effective R&D tax strategy. Ronald B Schrotenboer of Fenwick & West puts it all into perspective

Type of deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition £325 million ($518.5 million) CIT Property investment Portfolio of 11 shopping centres previously held by Charterhouse Herbert Smith, London, Neil Warriner, Rob Young Lovells, London, Richard Stones; Mayer Brown Rowe & Maw, Jeremy Clay Acquisition Undisclosed Barclays Charles Schwab Europe Simmons & Simmons, London, Edward Troup, Lisa Cristie Freshfields Bruckhaus Deringer, London, Francis Sandison Acquisition ?300 million ($324.5 million) DiBa Allgemeine Deutsche DirektBank Entrium Direct Bankers KPMG, Frankfurt, Christian Janisch, Matthias Hogh; Beiten Burkhardt Goerdeler, Frankfurt, Gunther Bredow; Lovells, Fankfurt, Jorg Siegels Hengeler Mueller, Frankfurt, Ernst Thomas Kraft Acquisition ?377 million ($407.8 million) OMV 313 Aral & BP filling stations from Deutsche BP; 45% stake in Bayernoil; 18% stake in Transalpine pipeline KPMG, Frankfurt, Christian Janisch, Marion Arndt Linklaters, Oppenhoff & Rädler, Munich, Florian Lechner, Jens Blumenberg Acquisition Undisclosed Cognis Degussa sale of operations in Hythe, Southampton, Barry recommended by EC for Degussa acquisition of Laporte. Cleary, Gottlieb, Steen & Hamilton, London, Julian Hickey Slaughter and May, London, Steve Edge, Edward Denny Acquisition ?100 million ($108 million) Pillar Retail and leisure park in the Nassica Complex owned by Neinver Uría & Menéndez, Madrid, Victor Viana In-house Disposal £848 million ($1.35 billion) GE Consumer Finance First National from Abbey National Linklaters, London, Yash Rupal, Jan Birtwell Slaughter and May, London, Graham Iversen, Clare Richardson Disposal Undisclosed Southern Water Investments Ltd First Aqua JVCo RBS - Linklaters, London, Martin Lynchehan, Liz Conway; Vivendi - Simmons & Simmons, UK, Nick Cronkshaw, Simon Yates, Martin Shah Clifford Chance, London, Douglas French Acquisition $2.4 billion Johnson & Johnson Scios Cravath Swaine & Moore, New York, Lewis Steinberg Latham & Watkins, Los Angeles, Laurence Stein, Silicon Valley, Joseph Yaffe Disposal ?560 million ($605 million) Nestlé Waters AS Watson & Co shareholding in Powwow Group White & Case, London, Anthony Concannon Baker & McKenzie, London, Alex Chadwick, James Smith Acquisition $675 million Bresnan Broadband Holdings Comcast Cable systems Paul Hastings, Janofsky & Walker Davis Polk & Wardwell, New York, Po Sit, Avishai Shachar, Christopher Peters, Avrohom Gelber, Menachem Neeman Acquisition £1.25 billion ($1.99 billion) Candover; Cinven Gala Group Ashurst Morris Crisp, London, Richard Palmer Clifford Chance, London, James Plummer Disposal $162 million Perenco UK BP's UK Southern North Sea gas assets Jones Day, New York, Vladimir Lechtman CMS Cameron McKenna, London, Richard Croker, Alison Hughes Disposal £95.3 million ($152 million) Moorfield & Westbrook Partners Woodside Estate from Woodside Limited Partnership Herbert Smith, London, Neil Warriner CMS Cameron McKenna, London, Mark Nichols Acquisition £70 million ($105 million) Graphite Capital Management Jane Norman Linklaters, London, Jan Birtwell, Simon Marks SJ Berwin, London, Michael Trask, Dominic Adams Disposal n/a Consortium private investors including Apax Partners, Goldman Sachs Capital Partners and Providence Equity Cable TV activities of Deutsche Telekom Debevoise & Plimpton, London, Peter Schuur; Frankfurt, Friedrich Hey; Freshfields Bruckhaus Deringer, Cologne, Stephan Eilers Hengeler Mueller, Frankfurt, Christof Jackle Acquisition ?335 million ($362.4 million) ABN AMRO, BNP Paribas, Credit Lyonnais, ING Bank, Rabobank International, RBOS, Societe Generale, West LB NV Casema from France Telecom Norton Rose, London, Dominic Stuttaford, Annastasia Bond Gunning Nauta Dutilh, Allen & Overy Acquisition ?1.95 billion ($2.1 billion) DSM Roche's vitamins and fine chemicals unit Cleary Gottlieb Steen & Hamilton Homburger; Davis Polk & Wardwell, London, John Paton, Christopher Peters Merger combined revenue $4.2 billion Prudential Financial; Wachovia Corp n/a Debevoise & Plimpton, New York, Seth Rosen n/a Acquisition $6.75 billion BP 50% stake in TNK KPMG, London, Andrew Gavan; Moscow, Jim McKinven, Olga Stergiopoulos; BP, Bernard Logue, Lawrence Hanna, Peter Broughal; Jones Day, New York, Vladimir Lechtman; London, John Clark, Amanda Long

The Australian government has implemented many incentives to encourage VC investment. Rick Taylor and Max Persson of Deloitte, reveal what it means for foreign investors and fund managers

After years of fierce debate, the European Savings Directive has reached a compromise on banking secrecy and withholding tax. John C Brouwer and Godfried JW Kinnegim of Allen & Overy investigate the intricacies

Until 2003 salary income of non-residents was taxed in Spain when:

Thanks to a recent decision by Germany's highest tax court, foreign employees temporarily transferred to a German group subsidiary will generally be entitled to receive government child support contributions (Kindergeld) for their children living in Germany if their income is subject to German social insurance contributions (Federal Tax Court judgment of October 30 2002 - VIII R 67/99).

Italy’s tax amnesty draws a line between the tax system of old and the new budgetary reforms. Francesco Florenzano and Barbara Faini of Baker & McKenzie explore taxpayers’ options

The Commissioner of Inland Revenue (CIR) announced in the January 2003 issue of The Hong Kong Accountant, the official journal of the Hong Kong Society of Accountants (HKSA) that the Inland Revenue Department (IRD) would initiate prosecution action whenever it is warranted to combat tax evasion. This is a result of the tough approach taken by the court in delivering judgment against those who were wilfully intended to evade tax, and the court put them in prison.