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A ruling by the European Court of Justice (ECJ) last year has put additional pressure on the Finnish government to amend the Finnish avoir fiscal system for dividend taxation. In the ruling, the ECJ found that the Dutch dividend tax system was incompatible with the EC Treaty. Although under the Finnish avoir fiscal system foreign dividends are treated differently than Finnish dividends, it has been argued that the Finnish system has a discriminatory effect.

The decision recently handed down by the European Court of Justice (ECJ) in the matter of AMID NV suggests that central aspects of German tax law on cross-border loss utilization are in violation of the freedom of establishment clause of the EC Treaty (article 43; formerly, article 52). As pointed out by Gert Saß (Der Betrieb 2001, 508), the judgment raises two questions:

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An increasing number of multinationals are implementing their stock option plans in Germany. There are both benefits for employees and tax consequences for the local German subsidiary. By Hans-Jörg Fischer, Deloitte & Touche, Frankfurt

New transfer pricing provisions were introduced in India as part of the Union Budget 2001. And not before time, in a country that is at the forefront of those reaping the benefits of globalization. By Mukesh Butani of Andersen, Mumbai

When changes to the ‘mixer’ regime were set in progress, UK corporations were left with a narrowing range of planning options. Some possibilities for a Dutch resident mixer are considered here. By Gay Deuchar and Frank van Hulsen, Ernst & Young’s International Tax Services department

I refer to your article on Ernst & Young's hiring of a number of former Baker & McKenzie tax partners in the US (International Tax Review, February 2001), one of whom was quoted as saying that Baker & McKenzie is like a ?mom and pop grocery store? compared to the big five audit firms in the international tax area. The facts do not support such a comparison. Having worked for a big five firm in the recent past, I know from experience that Baker & McKenzie's international tax advisory resources throughout the world compare very favorably to those of the big five, particularly in emerging markets such as Asia Pacific, Latin America and Eastern Europe. The big five have armies of tax professionals doing local compliance work, but when it comes to high quality international tax advice, Baker & McKenzie's resources ? ie, its 350 tax lawyers in 61 offices of a single global firm ? are second to none. Yours faithfully,

The European Commission has announced that it is to improve the tax regime for the cross-border provision of occupational pensions. The plans were announced at the Stockholm European Council, March 23-24, and form part of the Commission's strategy to open up the pan-European labour market by 2005, announced 28 February. They complement the Commission's draft directive of October 2000, which proposed allowing cross-border pension plans but did not cover tax issues. This directive is due to come into effect at the end of 2003.

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