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SJ Berwin has established a Paris office by poaching a private equity team from Salans Hertzfeld & Heilbronn.

It is widely known that the EU legislation applicable to VAT is contained in the Sixth VAT Directive (as amended), pursuant to which electricity is considered a tangible good. This means that sales of electricity can take place in the domestic and foreign markets, giving rise to domestic sales, imports, exports, intra-EU acquisitions or supplies. As a tangible good, electricity should also be capable of being transported. However, this conclusion, which is logical for movable goods, becomes doubtful in the case of electricity. As a result, different approaches have been adopted on a country-by-country basis. This treatment dates back to 1977 (Sixth VAT Directive) and refers to heavily regulated environments where supplies were basically domestic in nature with a limited number of operators. Now, 24 years later and in the midst of an EU-wide process of deregulation and liberalization, these rules are insufficient to cope with the variety of situations and growing complexity of the different markets.

It’s all very well having your QI status in place, but how will this affect your business in practical day-to-day terms? This two-part article takes a look at what being a QI actually means. 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

As part of its income tax reform process, Australia is applying entity taxation to trusts. But the move has been met with mixed feelings. By Michael Taylor-Sands of Baker & McKenzie in Melbourne

DATE TYPE OF DEAL VALUE ACQUIRER TARGET HOLDER ADVISERS TO TARGET ADVISERS TO ACQUIRER ADVISERS TO HOLDER 30/1/01 Acquisition $275 million ABN AMRO ING Barings North America ING Group Sullivan & Cromwell, New York, Ronald Creamer Davis Polk & Wardwell, New York, Dana Trier, Lin Shaw As for target 2/2/01 Acquisition A$1.1 billion ($574 million) British American Tobacco Minorities in BAT Australasia BAT Australasia N/A Blake Dawson, Australia, Kevin Barry, Sandra Lanigan, Peter McMahon, Sally Hines In-house 31/1/01 Proposed acquisition $1.2 billion Canadian National Railway Company Wisconsin Central Transportation N/A Sullivan & Cromwell, New York, Ronald Creamer Davis Polk & Wardwell, New York, Michael Mollerus 29/1/01 Acquisition $2.5 billion Maxim Integrated Products Inc Dallas Semiconductor Corp N/A Jenkins & Gilchrist, Dallas, William Bowers, Jeffry Blair Simpson Thacher Bartlett, New York, Charlie Rappaport, Nancy Mehlman 24/1/01 Aircraft financing $1.4 billion ABN AMRO ? agent for syndicate of banks financing 30 new Airbus aircraft for CIT N/A CIT Group N/A Denton Wilde Sapte, London, Paul White, Nick Chandler; In-house, Robert Cunningham, Douglas Scott; Paul Hastings, US, John Howitt In-house, Ira Finkelson and Todd Steiner; Holland & Knight, US, Rick Crowley 30/1/01 Acquisition £108 million ($155.7 million) Morley Fund Management Angel Court AP Fonden N/A Lovells, London

For foreign investors in Argentina, the question of whether business activities constitute a permanent establishment in the country is a crucial one. This special report outlines the definition, scope and practicalities of an Argentinian PE. By Daniel Albarellos and Horacio Dinice of Arthur Andersen, Buenos Aires

Tax reforms enacted during the time of economic boom are proving to be inappropriate in present-day China, which is still recovering from the difficulties of 1997 and contemplating accession to the WTO. As a result, the PRC government is now putting in place new reforms. By Matthew Mui and Ian Jia of PricewaterhouseCoopers, Beijing

Russian Prime Minister Mikhail Kasyanov has decided the fate of profit tax in Russia. Part two of the Russian tax code came into effect in January 2001, following the implementation of part one in 1999. But, while part two announced changes in VAT and personal income tax rates, and part one dealt with tax administration, the government failed, in either section, to agree on a new profit tax chapter. Two sections of the Russian government each produced a draft profit tax chapter and on February 7 2001, Kasyanov decided which of the two versions to develop. A working group is now amending the draft chapter, but it is unlikely to come into effect before January 2002.

Neil Woodgate, formerly a partner at Denton Wilde Sapte in London, has joined White & Case's London office.

The Swedish Ministry of Finance has proposed that capital gains taxation on shares qualifying for the participation exemption be abolished. In general, the participation exemption will apply to shareholdings in Swedish or foreign companies, which are quoted on a stock exchange if the holding is at least 10% and the shares are held for a minimum period of 12 months.