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  • The Credit Suisse group has struck a deal to acquire US investment bank Donaldson, Lufkin & Jenrette for $11.5 billion in cash and stock.
  • Four UK building societies that converted to banks in the late 1990s claimed tax deductions for the costs of converting. The Inland Revenue disputed this, but the Special Commissioners of Tax found in the building societies’ favour. Hartley Foster of Clifford Chance reports
  • International retailer Kingfisher has chosen Freshfields Bruckhaus Deringer to advise on the demerger of its general merchandising activities. Woolworths, Superdrug and Kingfisher Entertainment Group are among those members to be demerged. The DIY and electricals businesses, including B&Q, Castorama, Comet and Darty are to be retained. Tax partners, Richard Ballard and Helen Lethaby, both of the London office, are working on the £1 billion ($1.45 billion) deal. Partners James Vaudoyer of Paris and Robert Scarborough of New York are also advising on tax aspects.
  • Deborah Lange Senior vice-president, tax, Oracle Corporation: Deborah Lange was last month promoted to senior vice-president of tax at the US’ Oracle Corporation. She explains to Sharon Cunningham why, after 13 years with the leading technology company, her enthusiasm for the job has not wavered
  • The Granada merger with Compass in the UK involves an IPO, a public bid for a competitor, a demerger and a consolidation of public listings. The result is a huge tax challenge. Sandy Frew of Granada, and Daniel Friel and Karen Hughes of Lovells in London, review the tax issues
  • Certain Swedish regulations governing the taxation of income favour Swedish companies compared with foreign companies in the same situation. However, several changes have recently been proposed in a memorandum from the Ministry of Finance. The reason behind the proposal is Sweden's progression from a country where most groups of companies consisted of Swedish entities to one where more groups comprise foreign companies. Sweden must also comply with international undertakings prohibiting discrimination. The proposal concerns, amongst others, the areas listed below.
  • Qualification of simplified stock companies for the dividend withholding tax exemption
  • The German tax reform legislation taking effect in January 2001 (see International Tax Review, September 2000) creates a uniform corporation tax rate of 25% for all corporate earnings, whether distributed or retained, and whether earned by a domestic corporation, a dual resident corporation, or the domestic permanent establishment (ie a branch or a limited or general partnership) of a foreign corporation. While the new law trims only five percentage points off the corporation tax rate for distributed earnings, which falls from 30% to 25%, the rate for retained earnings and for the earnings of the domestic permanent establishment of a foreign corporation plunges by a whopping 15 percentage points, from 40% to 25%. With respect to permanent establishments, the 25% rate is definitive, since no branch profits tax applies and the repatriation of earnings triggers no withholding tax, even if treaty protection is unavailable.
  • Since Thailand introduced VAT in 1992, the Revenue Department has issued numerous individual rulings on tricky areas. Self-assessment has been a particular sticking point. By Kitipong Urapeepatanapong and Chaiyong Ngampravatdee, Baker & McKenzie, Bangkok
  • Australia introduced capital gains tax in 1985, but the question of how its provisions interact with those in tax treaties has never been put to the test. Ian Dinnison, KPMG Melbourne looks at a new draft ruling from the Australian Taxation Office