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Linklaters and leading Brazilian law firm Goulart Penteado, Iervolino e Lefosse ? Advogados (GPIL) have entered into a cooperation agreement to provide legal advice for both Brazilian and international clients.

Court decision: application of thin capitalization rules and tax treaties

DATE TYPE OF DEAL VALUE ACQUIRER TARGET HOLDER ADVISERS TO TARGET ADVISERS TO ACQUIRER ADVISERS TO HOLDER 25/06/01 acquisition $125 million Ultraframe plc Four Seasons Group n/a Ernst & Young, New York,

After a long wait, the World Trade Organization (WTO) has backed the EU in its trade dispute with the US, allowing the EU to go ahead with sanctions.

Clifford Chance has entered into an exclusive alliance with Italian tax boutique firm Vitali Romagnoli Piccardi e Associati to establish a stronger presence in Italy.

As increasing numbers of corporations operate on a pan-European basis, in-house tax departments and their advisers are looking to bodies such as the EU and OECD to make their work simpler. By Georgina Stanley

The Brazilian Federal Supreme Court (STF) has held that the imposition of services tax (ISS) on gross revenues derived from the lease of movable assets is unconstitutional. The decision was handed down on October 11 2000, but was not published in the official gazette until May 25 2001.

Ruling on a motion to stay collection of tax, the Federal Tax Court (FTC) has affirmed the existence of "serious doubts" as to the compatibility of Germany's codification of the transfer pricing arm's-length principle with the anti-discrimination provisions of article 52 ff (new article 43 ff – freedom of establishment) and article 73b ff (new article 56 ff – free movement of capital) of the EC Treaty. The ruling, dated June 21 2001, accordingly grants the taxpayer a stay of collection pending a judgment on the merits. German procedural law gives taxpayers a right to a stay where "serious doubts" exist as to the legality of the assessed tax.

Kazuo Taguchi has left Japan's National Tax Administration (NTA) to join Tokyo Aoyama Aoki Law Office/Baker & McKenzie's International Tax Practice.

A new comprehensive double taxation treaty between the UK and the US has been signed, replacing the current UK-US treaty, which has been in place now for more than 20 years.