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Chile recently introduced new tax law provisions. Whilst foreign institutional investors gain an exemption, a new thin capitalization rule along with limitations on certain taxplanning techniques show the authorities’ more stringent approach to the subject of tax avoidance. By Leon Larrain and Miguel Zamora, Baker & McKenzie, Santiago

The Lovells tax practice comprises 11 tax partners and 16 associates. Lovells provides a comprehensive range of international and domestic business and corporate tax planning services. The firm has its own tax capability in the offices listed below.

Our tax and legal specialists help you to gain business advantage by providing multidisciplinary and innovative solutions to your business challenges.

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Stockholm office

Foreign-funded banks and financial institutions established and operating in special economic zones (SEZs) including Shanghai Pudong and the Shuzhou Industrial Park have enjoyed a special exemption from business tax on their revenue from foreign exchange lending since 1997, under the Notice on Issues Concerning Adjustment of Taxation Policies for the Financial and Insurance Industries, Guo Fa [1997] No 5, issued by the State Council in the same year. Guo Fa [1997] No 5 provided that foreign-funded banks and financial institutions established and operating in SEZs would be exempted from business tax for five years from the date of registration of the relevant bank institution in respect of their turnover sourced from inside SEZs (the five-year exemption).

The avoir fiscal system and the new German half income procedure may make it attractive for non-German shareholders of French corporations to channel their dividend income through a German resident corporation. By Hubert Schmid and Thomas Dammer, Clifford Chance Pünder, Frankfurt

Lovells is to merge with French firm Siméon & Associés. Siméon's offices ? in France and Belgium ? will merge into the respective Lovells' offices on November 1 this year. The firm will be known worldwide as Lovells. The merger will give Lovells five full-time tax lawyers in Paris. Siméon tax lawyers Claire Guionnet-Moalic and Florian Delisle will join existing partner Hervé Israel and his two assistants. Jean-Pierre Langlais, a corporate partner responsible for overseeing the tax practice at Siméon, will also assist the team.

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.

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,