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  • 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
  • Legislation enacted in 2000 gives Germany’s tax auditors sweeping electronic audit rights from 2002 onwards. Most taxpayers have yet to realize the potentially dire transfer pricing implications. By Alexander Vögele and William Bader for KPMG, Frankfurt
  • The UK Inland Revenue and Customs and Excise are to be given powers to fight crime.
  • SJ Berwin has established a Paris office by poaching a private equity team from Salans Hertzfeld & Heilbronn.
  • EU action on harmful tax competition has taken a significant step forwards. The rollback of measures with harmful features is now possible as early as 2002. By Heleen Nijkamp, chair of Ernst & Young’s EU Tax Steering Committee, New York
  • 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
  • The US is to negotiate new tax treaties with Hungary and Australia.
  • The controlled companies provisions in Hong Kong's Estate Duty Ordinance were designed to counteract avoidance of estate duty. In general terms, a proportion of the Hong Kong assets of a controlled company would be deemed to be included in the property passing on the death of a deceased and chargeable to estate duty. However, the scope of the provisions was so widely drawn that it could catch many innocent transactions. On the premise that the provisions were not for generating revenue, the Inland Revenue Department reassures in its Interpretation and Practice Note, issued on December 21 2000, its policy that the provisions would only be invoked where there is patently an attempt to avoid estate duty.
  • Until recently most foreign investors making direct capital investments in Brazil were automatically protected against exchange losses. This was because the Brazilian Central Bank used to issue a foreign capital certificate guaranteeing that the original US dollar amount invested could be repatriated tax free as long as there was no deterioration of the company's net worth.
  • The US Internal Revenue Service has proposed new rules governing the opinions tax advisers are allowed to offer their clients with regard to tax shelters. By Keith Martin Chadbourne & Parke LLP, Washington