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John Baldry, barrister with international law firm Allen & Overy, reports on the decision of the High Court in a recent anti-avoidance case, Griffin v Citibank Investments Limited, and outlines the history of substance over form in the UK

The first amendments have been drafted to the German Tax Reform Act concerning domestic share and derivatives trading

The UK Inland Revenue has closed one million tax files because it is missing vital information. The files were lost following the April merger of the Inland Revenue and the Benefits Agency, and affect the tax year 1997-98. The loss could affect employees' assessments for pensions and other benefits.

According to OECD data, tax revenues from personal and corporate income taxes have risen markedly in most OECD countries in the late 1990s. The strongest growth was in 1997-1998 when the OECD average increased from 13.2% in 1997 to 13.5% in 1998.

The Hong Kong revenue service is to put into effect the double taxation relief provision in the air services agreements with Denmark, Sweden and Norway

UK Chancellor Gordon Brown's pre-budget speech amounts to almost a £5 billion ($7.2 billion) give-away.

A tax ruling issued by the Singapore tax authorities affects businesses distributing digitized products via the internet to Singapore customers. The ruling, entitled Income Tax Guide on E-Commerce, issued on August 31 2000, states that payments made to non-residents for the use of digitized products are subject to Singapore withholding tax, even though the selling company has no physical business activities carried out in Singapore. While the desire to protect the tax base from erosion is understandable, the August ruling did not address the fundamental distinction between a sale of copyrighted goods and a license of intellectual property. This was partially addressed when the government announced on November 11 2000 that payments for "shrink-wrap" software will be exempt from withholding tax with effect from January 1 2001. It is, however, unclear whether the proposed exemption extends to shrink-wrap software distributed via the internet.

Sullivan & Cromwell has advised Royal Philips Electronics on its $1.7 billion agreed acquisition of Agilent Technologies Healthcare Solutions Group.

FedEx, the Memphis-based global transportation and logistics company, is bidding $1.2 billion in cash, stock and assumed debt to acquire the less-than-truckload commodities carrier, American Freightways.

Davis Polk & Wardwell has advised Italian banking group Sanpaolo IMI SpA on its EUR1 billion ($860 million) offering of trust preferred securities outside the US.