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Tokumei kumiai arrangements continue to be a versatile planning technique for achieving a wide range of business and tax structuring objectives. This article looks at their use in Japan, and at the increase in tax audit scrutiny of TK arrangements. By Dean A Yoost and Todd Landau, PricewaterhouseCoopers, Tokyo and New York

As the UK’s Labour government is voted in for a second term of office, it is time to review the failures and gains of previous tax incentives, and take some bold steps to ensure future growth. Without some major changes, inward investors will go elsewhere. By Sian Sandeman and Heather Self, Ernst & Young, London

The new US rules for withholding tax aim to substantially change the way that withholding tax is accounted for and administered. Will positive first impressions pan out? By Michael A Cashman, Morgan Lewis, London

A decision handed down in early May 2001 by Germany's highest tax court indicates that key provisions of the proposed regulations on transfer pricing documentation requirements have no legal foundation and are therefore invalid. (See articles on the proposed regulations by Alexander Vögele in the January and February 2001 issues of International Tax Review, pp. 38 and 17 respectively.) Further delay in issuing final documentation regulations may now be expected as the Federal Ministry of Finance strives to assess the impact of the Federal Tax Court (FTC) decision on its transfer pricing policies.

The Portuguese government has released a revision to securitization laws that will encourage many more deals in the country

Dividends received by an operating Swedish company from a foreign company are exempt from Swedish corporate tax if the receiving company holds at least 25% of the voting rights in the distributing company at the end of the tax year, or it is made probable that the shares are held as a trade investment. The foreign company must also be subject to a tax comparable to Swedish tax (that is, a tax levied at a rate of at least 15%).

In a comprehensive strategy paper examining the EU's future taxation policy, the European Commission (EC) has claimed that increased tax coordination within the EU would help member states to meet the objectives of making Europe the most competitive economy in the world by 2010. However, while it believes that a large measure of harmonization is necessary in the fields of value-added tax (VAT) and excise, the EC stresses that in other tax fields, coordination does not imply tax harmonization. The statement states: ?A reasonable degree of tax competition within the EU is healthy and should be permitted.?

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Kriss Bush has resigned from his role as financial director of Lehman Brothers in London and will this month be heading to Toronto to assume the role of senior vice-president of tax for Nortel Networks. The move sees Bush returning to the more familiar territory of hi-tech tax: prior to his appointment at Lehman Brothers last summer, he was group tax director with Cable & Wireless in London.

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