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PricewaterhouseCoopers has been practicing in Latin America for nearly a century, with its first office opening in the region in 1906. With a Latin American network of over 12,000 professionals and the largest market share of any other services organization in the region, PricewaterhouseCoopers is positioned to assist companies with respect to their business activities throughout Latin America.

White & Case has completed two debt offerings from the Nordic region totalling $1.3 billion. In the first deal White & Case represented Finnish forest products company UPM-Kynmene in a $500 million offering of senior notes. Deutsche Bank Securities acted as the manager. On the second deal the firm represented Merrill Lynch, Salomon Smith Barney and Credit Suisse First Boston as managers in an $800 million offering by Nordea Bank Sweden.

Korea has revised treaties with Germany, and Jordan and is considering amending its treaty with Malaysia

Following the lead of the Isle of Man earlier this year and Jersey in mid-November, Guernsey has revealed plans to reduce general corporate tax to 0%

The High Court has recently dismissed a taxpayer's application for judicial review in relation to the seizure and removal of computer equipment from his home by the Inland Revenue.

Under domestic law, capital gains realized by a non-resident on the sale of shares in a non-resident entity are not subject to Spanish tax, irrespective of the nature and location of the assets owned by the non-resident entity. Thus, capital gains obtained by non-residents on the sale of shares of non-resident entities holding indirectly Spanish real estate (that is, through another entity) are not taxed in Spain.

The tax authorities have addressed, in a ruling issued on October 24 2002 (the Ruling), the tax regime applicable to vehicles incorporated pursuant to the so-called Securitization Law (law no130 of April 30 1999) in order to carry out securitization transactions (the securitization vehicles). Although the Ruling is binding only for the applicant, the principles set forth by same Ruling are helpful in understanding the Italian tax authorities' view, because to date they have not issued any generally binding guidelines.

ECJ CONFIRMS GERMAN THIN CAP LAW IS DISCRIMINATORY

The Inland Revenue Department issued a departmental and interpretation note (DIPN) no 40 entitled "Profits Tax - Prepaid or Deferred Revenue Expenses" outlining the department's view and the change of practice on the treatment of prepaid and deferred revenue expenses. It has been a common practice to allow a deduction by way of a computational adjustment for the whole amount of a prepaid expense in the year it was incurred even if the expense was not charged to the taxpayer's profit and loss account.

The State Administration of Foreign Exchange has issued new regulations on the administration of foreign exchange on July 25 2002. The new rules allow distribution companies, processing companies whose products are sold to the domestic market and companies whose registered capitals were injected in renminbi to purchase foreign currency for payment of normal trade transactions. Previously, Free Trade Zone (FTZ) companies were not allowed to purchase currency for payment to overseas entities or non-FTZ companies.