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  • Treasury responds to the WTO decisions on the US extraterritorial income exclusion regime and the SEC adopts final rules to implement Title II of the Sarbanes-Oxley Act. By Margie Rollinson, David Benson and Peg O'Connor of Ernst & Young
  • The 2003 Finance Bill is likely to introduce new rules on corporation tax on UK branches of foreign corporations. Colin Clavey and Siân Morgan of Ernst & Young analyze the legislation and the Inland Revenue's plans
  • 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
  • According to news reports, Bosnia is overhauling its customs system in the hope of finding millions of dollars of unpaid excise taxes. Paddy Ashdown, Bosnia-Herzegovina's High Commissioner, reportedly said that the county was losing KM1.4 billion ($770 million) a year to custom and tax fraud.
  • 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
  • The SEC is suing KPMG and four KPMG partners including the head of the firm's department of professional practice for fraud. The charges relate to KPMG's audits of Xerox from 1997 to 2000.
  • by Edward Troup, Head of Tax Strategy, Simmons & Simmons
  • The OECD Committee on Fiscal Affairs recently issued the January 2003 version of the Model Tax Convention on Income and on Capital (the Model Convention). This version includes the text of the Model Convention as it read on January 28 2003 and has various significant points; one of the most interesting is Mexico's new observation with regard to the commentary on article 12 (royalties) of the Model Convention, which reads as follows:
  • The Italian tax authorities have confirmed, in circular letter 8/E issued on February 6 2003 (the Ruling), the de facto tax neutrality of vehicles incorporated pursuant to the so-called Securitization Law (law 130 of April 30 1999) in order to carry out securitization transactions (Securitization Vehicles).
  • 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.