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Freedom of establishment – Tax legislation law – Direct taxes – Deduction of business losses – Previous tax year.

The merger will provide the largest European stock market, with 53% of traded volume.

The proposed merger will be achieved via a cash and share offer by an AMEC group company valuing AGRA at C$514 million ($341 million). If the deal closes, the merger will create a leading international group providing design services, applied technology and project delivery to the global engineering, construction and environmental industries. Combined revenue will be approximately C$8.8 billion from continuing operations.

New Saudi tax reforms attempt to balance the need for alternative sources of income with the desire for more foreign investment in the private sector.

The Finance Act 1999 introduced, for the first time, specific provisions regarding taxation of employee stock options and other specified securities allotted by an employer to employees. Accordingly, the value of any specified security (employee stock options and certain other prescribed securities) allotted or transferred, directly or indirectly, by an employer free of cost or at a concessional rate, to an individual who is or has been in their employment, would constitute a taxable perquisite in the year of exercise/allotment. The value of the perquisite would be the difference between the fair market value and the cost of acquiring the specified securities. Further, the capital gains, if any, from a subsequent sale of shares arising on exercise of stock options, would be computed on the basis that their cost of acquisition is the fair market value on the date on which the stock option was exercised.

In a judgment published in March, the Federal Tax Court rebuffed challenges by the German tax authorities to dividend stripping schemes handled through a German broker firm. The transactions involved were of two types. In one case, foreign taxpayers holding shares in German corporations sold these shares to the German broker shortly before the dividend payment date and then repurchased the shares in a separate transaction after the dividend distribution at a correspondingly lower price. In the other case, sale and repurchase were effected on the same day. Instead of repurchasing the same shares, the foreign shareholders repurchased newly-issued shares not entitled to participate in the impending dividend. In both cases, the sale and repurchase transactions were effected through intermediary banks over the stock exchange. The transactions at issue took place between 1989 and 1991.

A simplified foreign investment regime is opening up a number of expat tax opportunities.

Canada Customs and Revenue Agency (CCRA) recently released schedule 91, a supplementary schedule to the filing required of non-residents claiming treaty exemption from taxation in Canada. Canadian tax return filings are required within six months of year-end for years starting after 1998, where a non-resident is carrying on business in Canada or disposes of taxable Canadian property. Penalties will be imposed if the non-resident is found to be in non-compliance.

The UK’s decision to defer its restrictions on the use of mixers is a positive but not a definitive step. Industry should continue to lobby – just in case

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