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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

MAINLAND CHINA

Options and cost-sharing:

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.

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.

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.

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