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The Finnish Act on Income Taxation (1535/1992) was amended by the Act on Amending the Act on Income Taxation (1165/2000), that entered into force on January 1 2001. The central provision to be amended was the definition of foreign earned income (ulkomaantyötulo). Foreign earned income was previously defined as income received by a person otherwise generally liable to pay tax in Finland from working abroad, provided that the stay of this employee abroad is directly due to such work and the stay abroad lasts for at least six months uninterrupted (the so-called 'six months' rule'). According to the new provision, income received as an employee stock option benefit or as a benefit due to the right to subscribe for shares in a corporation at a price lower than current value (employee share issue) is no longer considered as foreign earned income unless:

In last month’s article, the authors discussed the tricky question of what constitutes a QI and recently issued guidance by the IRS. Part two of this article answers frequently asked questions about the day-to-day application of the QI rules and addresses the need not to be complacent, By Philip Marcovici and Marnin Michaels of Baker & McKenzie’s Zurich office, Thomas O’Donnell in the Paris office and David Balaban and Peter Connors of Baker & McKenzie in New York

Four partners are to quit the Hamburg office of Andersen Luther, the German member firm of Andersen Legal's network, at the end of June to launch their own legal practice in the city.

Last year's merger of Clifford Chance with Pünder Volhard Weber & Axster has ended in disaster for Clifford Chance in Warsaw, with the Pünder team moving to Beiten Burkhardt Mittl & Wegener (BBLP). A total of 16 Pünder personnel will join the BBLP on April 1 2001. This includes two tax advisers, and with a lateral hire yet to be announced, will bring the number of tax specialists at BBLP, Warsaw, to four.

The UK Chancellor Gordon Brown presented his 2001 budget on March 7 2001. The budget measures contained few surprises, most having been announced in the pre-budget report in November 2000, but a number of new initiatives for the future were announced. The main corporation tax rate of 30% and the reduced rates of 20% and 10% for companies with low profits are unchanged for 2001/2 and 2002/3.

The globalization of business has meant that the number of foreign individuals entering Brazil to work at subsidiaries of major multinational companies has increased considerably. Consequently, immigration requirements and individual income tax regulations are key issues facing companies planning their investment strategy in Brazil. The privatization process of the electricity, energy and telecommunications sectors, together with the overall opening up of the Brazilian economy have all precipitated a number of changes in the relevant legislation.

The Finance Minister of India, as part of the Union Budget 2001 proposals, has introduced new provisions in the Income Tax Act, 1961, to curb tax avoidance by the abuse of transfer pricing. If legislated, these would be applicable for the financial year commencing April 1 2001.

The distinction between tax avoidance and tax evasion is a key one in Italy’s criminal justice system, By Professor Astolfo Di Amato and Roberto Pisano, of Astolfo Di Amato e Associati, Rome and Milan

Corporate and private tax regime changes in Austria aim to improve national budgetary figures, as well as introduce new regulations for employee shareholdings and investment funds, By Herbert Buzanich and Michael Sedlaczek of Freshfields Bruckhaus Deringer, Vienna

Structured finance lawyers in Italy are swamped with securitizations, as originators rush to close deals before a favourable accounting benefit comes to an end in May