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Tax obstacles to securitization are to be abolished in Germany but true-sale transactions will require careful structuring. Florian Schultz and Martin Krause of Linklaters Oppenhoff & Rädler explain why

Japan's struggling banks have been granted a temporary reprieve after winning a High Court tax case against the Tokyo city government. The court ruled that taxes imposed by Tokyo city on banks were illegal and if this decision is upheld by the Supreme Court, the banks could see around ¥160 billion ($1.4 billion) returned to them.

by Edward Troup, Head of Tax Strategy, Simmons & Simmons

The effects of Sarbanes-Oxley have spread to Europe as PricewaterhouseCoopers' associated law firm Landwell, last month lost the majority of its tax litigation group in the UK as a result of the US legislation. A six-lawyer team and support staff have joined US firm Dorsey & Whitney in London because of fears that the US legislation would leave them unable to work with their biggest clients. But while Landwell, UK, has suffered, most of big four's associated law firms' litigation groups have escaped unscathed.

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:

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.

Attempts to introduce a new income tax in Bolivia collapsed after violent strikes left more than 10 people dead and many more injured in the capital city, La Paz. The Bolivian president Gonzalo Sanchez, announced that he was abandoning his Budget in light of the violent demonstrations in the city. The country descended into violence after the government announced its intention to bring in a tax of 12.5% to reduce the budget deficit.

India's prime minister wants to introduce a tax on international currency transactions in order to protect developing economies. Atal Behari Vajpayee called for the tax after blaming currency speculators for the economic crises in Mexico, Southeast Asia, Brazil and Argentina. He reportedly claimed that it would help protect weak economies from capital volatility, enhance investor confidence through greater stability and generate developmental resources.

The European Commission last week decided that tax breaks in Belgium, Ireland and the Netherlands constitute state aid

Despite the obvious advantages of a network when it comes to transfer pricing work, two leading transfer pricing professionals have left the big four for smaller consulting firms