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The Ministry of Finance announced the tax reform plan for 2003 on December 19 2002. The proposed changes include the following items.

In its decision of January 22 2003 in what is known as the Pirelli case, the UK High Court rejected a claim by the Inland Revenue that companies that would otherwise be entitled to compensation in respect of advance corporation tax (ACT) paid on dividends to the parent companies in the EU on the basis of the European Court of Justice decision in the Hoechst case, should be denied such compensation or be subject to an offsetting reduction if the group was entitled to a tax credit refund under a double tax treaty between the UK and the country in which the parent company was resident. The court also decided that it was not necessary at this stage to refer to the European Court of Justice (ECJ) the issue as to whether ACT was a withholding tax. This decision is subject to appeal.

The Brazilian government issued Provisional Measure 66/2002 (PM 66/2002) on August 29 2002. Among several other changes, PM 66/2002 had altered the rules for the application of the social integration program tax (PIS), and introduced new provisions with respect to tax avoidance.

Companies doing business in Argentina in 2002 were affected by a dramatic change of the applicable legal framework.

Retailer Marks & Spencer may have lost its tax appeal against the UK Inland Revenue, but it is not all bad news for companies looking for equal treatment throughout the EU.

After years of squabbling, the EU has managed to agree on new rules on the taxation of the savings of EU residents invested abroad

VAT – Article 13A(1)(c) of the Sixth Directive 77/388/EEC – Exemption – Concept of the provision of medical care – Treatment having no therapeutic aim – Interventions by a doctor acting as an expert.

Free movement - Freedom of establishment - Company incorporated under the laws of one member state and having its registered office there - Company establishing a branch in another member state in order to carry on its activities entirely or almost entirely in that member state - Form of registration in the commercial register - Justification.

Following renewed opposition to stock options by two US senators, many lawyers believe a law forcing companies to record such options as an expense is increasingly likely

Taxation - Directive 90/435 - Parent companies and subsidiaries of different member states - Common system of taxation - Distribution of dividends - Anglo-Dutch Convention for the avoidance of double taxation - Tax credit - Withholding tax of 5% in value of dividends and tax credit - Compatibility with the directive.