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Luis Liñero, Arthur Andersen, Mexico City

The German tax rules in force prior to enactment of the landmark German tax reform package reported on in the September 2000 issue of International Tax Review generally permit the purchaser of a German corporation to reorganize the corporation as a partnership at no income tax cost, and thereby obtain a step-up in the basis of the disappearing corporation's assets. The step-up includes previously non-capitalized intangibles, such as self-generated goodwill, and creates additional depreciation volume for personal or corporate income tax purposes, but not trade tax purposes, where the disappearing corporation's outside basis (price paid for its shares) exceeds its inside basis (book value of its assets).

The most radical Russian tax reform in 10 years is now in effect. The 13% flat tax rate, announced in July 2000, came into force at the beginning of January.

Recent developments in Ireland's tax regime, including changes announced in the Budget, show a determination to continue courting foreign investment. Gary O'Mahony of Ernst & Young, Dublin investigates the latest initiatives

Payments that are not otherwise chargeable to profits tax that have been received for the "use of" or "right to use" a patent, design, trademark, copyright, etc in Hong Kong are deemed to be taxable income. The tax commissioner considered that where a Hong Kong business could be said to have incurred royalty expenses in producing its Hong Kong sourced profits, the intellectual property concerned must have been used in Hong Kong.

The German Supreme Tax Court has overturned a recent decision by a lower court on the treatment of trademark royalties. Thomas Borstell and Oliver Wehnert of Ernst & Young's Transfer Pricing Specialist Group in Düsseldorf, report on the court's findings

An insider's guide to four of the more interesting transactions of 2000

The UK media company Carlton Communications has announced that contracts have been signed with Thomson for the proposed disposal of Technicolor. The transaction values Technicolor at $2.1 billion and is subject to shareholder approval.

Norway's ruling Labour Party and the central coalition have agreed on Budget amendments for 2001. The main amendments are described below.

Michael Walutes has joined Morgan Lewis & Bockius in New York as a partner in the tax practice group. He was formerly special counsel at Sullivan & Cromwell, also in New York.