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  • Victory for Foreign Banks
    In June 1997, the Chinese government announced its intention to collect a withholding tax of 10% on interest derived by foreign banks on offshore inter-bank loans on-lent to their branches in China.
    February 01, 1998
  • Changes to tax on passive income and individual taxation
    France's finance Act for 1998, applicable to 1997 income, is characterized by the suspension of the tax reduction plan announced by the previous government (personal income tax rate maintained at the maximum of 54%), and by an increase in the taxation of passive income.
    February 01, 1998
  • Switzerland returns to form
    Tax reform in Switzerland has revitalized the Swiss holding company regime. Peter Riedweg of Homburger Rechtsanwälte, Zurich looks at some of the regime’s new features, which include a capital gains tax exemption for qualifying participations
    February 01, 1998
  • Table 1
    Redesigning the global corporation
    As the globalization of US multinationals proceeds at an ever-faster pace, tax planning opportunities can sometimes be overlooked. Capital restructuring is one such opportunity. Eli Fink and Eric Overman, Deloitte & Touche, New York examine the potential tax savings
    February 01, 1998
  • Gibraltar bids for captive market
    Captive insurance can be an efficient vehicle for protecting companies against risk. Chris Johnson of Norwich Union, Gibraltar examines the options on offer, the role of tax in reducing costs, and the appeal of Gibraltar as a domicile for the captive owner
    February 01, 1998
  • ACT lives on – in the shadows
    The problem of surplus advance corporation tax has long been the bane of the UK multinational’s life. Now the ACT system is set for abolition. Murray Clayson of Freshfields, London considers the consequences, and the likely form of a successor shadow system
    February 01, 1998
  • Reed Elsevier disposal of IPC Magazines to Cinven
    Reed Elsevier is to dispose of its consumer magazine group IPC in a deal worth £860 million ($1.38 billion). The purchasing MBO group is financed by Cinven, with debt underwritten by Goldman Sachs. Freshfields acted for Reed Elsevier, with tax advice from partner Colin Hargreaves and manager Isabel de May.
    February 01, 1998
  • Burton Group demerger
    UK department store Debenhams is to be introduced to the London Stock Exchange, following its demerger from The Burton Group. It is expected to have a market capitalization of approximately £1.5 billion ($2.4 million).
    February 01, 1998
  • Korea: variations on OECD theme
    Korea’s International Tax Coordination Law updates the country’s transfer pricing regime, to deal with a growing volume of international transactions. Brian Park of Price Waterhouse, Seoul looks at the detailed requirements of the regime
    February 01, 1998
  • Société Générale acquisition of Hambros Banking Group
    Société Générale has acquired Hambros Banking Group from Hambro in a deal worth £300 million ($483 million). The banking group includes Hambros bank and its subsidiaries and associates, together with shareholdings in certain other companies. Société Générale was advised by tax partner Francis Sandison at Freshfields in London. Norton Rose acted for Hambro. Tax advice came from partner Louise Higginbottom and assistants Dominic Stuttaford, Nick Stretch and Mark Middleditch.
    February 01, 1998
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