Search results for

KPMG has set up a new team in New York to advise clients on Chinese tax law

China may revise the rate of tax imposed on advertising following a sharp slowdown in the growth of company spending on the area

Ashurst Morris Crisp has boosted its European tax practice with a lateral hire in Italy and a new office in Germany. Richard Engl has folded his tax consultancy firm RLE to join Ashursts as a partner-level steuerberater (tax adviser) in Munich. The office opened on May 2 and Engl brought three assistants from his previous firm with him. Litigation partner Karl Wach, previously at Linklaters, also joined the office.

New York firm Debevoise & Plimpton is to open an office in Frankfurt. The office will open this summer with three Debevoise corporate partners, Thomas Schurrle, a corporate partner from Norr Stiefenhofer Lutz, and Dr Friedrich Hey, a tax partner who left the New York office of Linklaters Oppenhoff & Rädler at the end of last year. He will be joining the firm in August after finishing his gardening leave, and will spend several months in New York getting to know the people so that he is better able to provide international advice before moving to Frankfurt later in the year.

Having already backed out of the Kyoto agreement, the US has now thrown the OECD's initiative against harmful tax practices into question. US Treasury Secretary Paul O'Neill issued a statement on May 10, stating that the US will not be backing the OECD initiative as it stands and calling for amendments to the proposal.

DATE TYPE OF DEAL VALUE ACQUIRER TARGET HOLDER ADVISERS TO TARGET ADVISERS TO ACQUIRER ADVISERS TO HOLDER 26/05/01 acquisition $675 million Old Mutual, UK St Paul Companies Inc n/a Sullivan & Cromwell, Bill Indoe, Sara McLeod, Terry O'Reilly Weil Gotshal & Manges, New York, Kenneth Heitner, Scott Sontag 25/05/01 merger £28 billion ($39.9 billion) Halifax Bank of Scotland n/a Herbert Smith, London, Bradley Phillips, Nikol Davies Linklaters & Alliance, London, Tom Scott n/a 21/05/01 joint venture EUR4.5 billion ($3.9 billion) n/a n/a Matra BAe Dynamics, Alenia Marconi Systems n/a n/a BAe Systems, Linklaters & Alliance, London, Ian Bowler, Dominic Winter, Elliot Weston; KPMG, London, Caroline Austin, Alex Priestley. EADS, Clifford Chance, London, David Harkness, Alice Gamble. Alenia Marconi Systems, Ashurst Morris Crisp, London Richard Palmer, Kate Eveleigh 11/05/01 global offering $1.8 billion Merrill Lynch, UBS Warburg SunAmerica Life Insurance Company GIC-backed notes and auction market equity securities AIG SunAmerica Global Financing n/a Davis Polk & Wardwell, New York, Po Sit, Michael Farber, Roy Caner O'Melveny & Myers, Los Angeles, Dean Weiner 09/05/01 rights issue £5.9 billion ($8.4 billion) n/a BT (British Telecommunications) n/a Linklaters & Alliance, London, Tom Scott, Mark Kingstone, Stephen Pevsner, Lynne Walkington; Shearman & Sterling, London, Bernie Pistillo; In-house, John Clark, Simon Coward n/a n/a 08/05/01 acquisition $408 million Cypress Group, US, Carlyle Group, US, holding company MedPointe Capital Partners Carter-Wallace Inc, Pharmaceutical division n/a Sullivan & Cromwell, New York, Ron Creamer, John Sweet Simpson Thacher & Bartlett, New York, Charles Rappaport, Adam Rosenzweig n/a 08/05/01 acquisition $739 million Church & Dwight, US, Kelso & Co, US, holding company Armkel Llc consumer brands of Carter-Wallace Inc n/a Sullivan & Cromwell, New York, Ron Creamer, John Sweet Gibson Dunn & Crutcher, Dallas, Jeff Trinklein, Misty Burns; Skadden Arps, Slate Meagher & Flom n/a 07/05/01 acquisition $6 billion Valero Energy Corporation Ultramar Diamond Shamrock n/a Jones Day Reavis & Pogue, Cleveland, Carl Jenks; Washington, Candace Ridgway; Wachtell, Lipton, Rosen & Katz, New York, Jared Rusman 04/05/01 demutualization and flotation £4.2 billion ($5.99 billion) n/a Friends Provident Friends Provident plc Herbert Smith, London, Ross Fraser, Howard Murray, Zoe Brown; PricewaterhouseCoopers, London, Lindsay J'afari-pak, Peter Hoye n/a n/a 03/05/01 acquisition £4.8 billion ($6.8 billion) Vodafone Group Plc BT interests in Japan Telecom, J-Phone, Airtel BT Bird & Bird, London, Richard Ward; BT in-house, London, John Clark, Simon Coward Linklaters & Alliance, London, Andrew Beverley, David Blumenthal; Sullivan & Cromwell 30/04/01 acquisition $1 billion Maxtor Corp Quantum HDD Quantum Corp Wilson Sonsini Goodrich & Rosati, Palo Alto, Ronald Roth Gray Cary, Palo Alto, Dave Plewa 25/04/01 security offering £1.2 billion ($1.7 billion) n/a equity and debt securities in Cazenove n/a Slaughter and May, London, Howard Nowlan n/a n/a 24/04/01 acquisition £150 million ($214 million) Siemens Mannesmann UK Vodafone In-house, Klaus-Peter Husgen; KPMG, Anneli Collins In-house, Regine Nowack, Stephen Beckett; Norton Rose, London, Christopher Norfolk, Rupert Shires 11/04/01 acquisition £130 million ($185 million) Wilson Connolly Holdings plc Wainhomes n/a KPMG Liverpool/Manchester, Malcolm Edge; McGreggor Donald KPMG, London, Margaret Stephens, Gary Jones; Wragge & Co, London, Jeremy Millington 05/04/01 acquisition $1.5 billion Suiza Foods Corp Dean Food Co n/a Kirkland & Ellis, Chicago, Keith Villmow Hughes & Luce, Dallas, Ronald Kerridge; 04/04/01 acquisition £810 million ($1.15 billion) Bass Plc Posthouse Hotel chain Compass Group Freshfields, London, Tim Crossley, Francis Sandison Linklaters & Alliance, London, Charles Hellier, Kathryn Farthing

Sales of goods manufactured in the US or other countries are still the most common way to cover the Mexican demand for raw materials or already processed products. However, in the last few decades, the incorporation of subsidiaries in Mexico has been changing this situation – the product is available in Mexico for the Mexican client or even for export activities. Further, over the last few years, a different approach has entered the arena – the just-in-time idea – through which inventories are owned by a non-resident entity in a warehouse in Mexico. The first tax question for just-in-time holdings is that of whether a permanent establishment exists when the non-resident has a warehouse in Mexico to deliver goods to its clients, but closes every sale directly with the customer from abroad. The author takes the view that no permanent establishment has been created and therefore no income tax should be paid in Mexico.

Finland levies asset transfer tax at a rate of 1.6% of the relevant market value on the transfer of Finnish securities. Excluded from asset transfer taxation are:

Does article 17 of the OECD model convention have its basis in outdated and discriminatory assumptions about artistes and athletes? Hold on to your hats for a whistle stop tour of its development, its lack of fit with the modern world and reasons for its repeal. By Joel Nitikman, Fraser Milner Casgrain LLP, Vancouver

Germany’s Federal Ministry of Finance has changed taxation on the sale of and disregarded a recent court ruling for convertible and exchangeable bonds. By Florian Schultz, Linklaters Oppenhoff & Rädler, Frankfurt