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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

On December 12 2002 the Court of Appeal delivered its judgment in the case of Mansworth v Jelley ([2003] STC 53). The court held that where an employee exercised unapproved share options granted by their employer or otherwise than by way of bargain at arm's length, the base cost in the shares should be treated as being the market value of the shares at the time of exercise of the option.

A new local enterprise taxation system will be introduced in Japan for tax years after April 1 2004, where a corporation will be taxed based on the size of its businesses measured by the value added, its capital, and its income. Under the new taxation system, a corporation with a tax loss will have to pay local enterprise tax. The new system is briefly summarized as follows.

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.