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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,

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.

On October 26 1999, the Dutch government proposed new legislation regarding the fiscal unity tax facility in the Dutch Corporate Income Tax Act (see International Tax Review, December/January 2000). The Dutch fiscal unity concept permits companies to apply for a tax consolidation of their wholly-owned subsidiaries, so that they can be treated as a single taxpayer and file one tax return.

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

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