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The issue was registered with the Securities and Exchange Commission and is therefore open to US holders of Telewest shares. In a connected move, Microsoft and the Liberty Media Group acquired 51.3% of the rights issue, thereby allowing Microsoft to take a stake in Telewest.

The UK Inland Revenue issued a press release on January 14 announcing that legislation would be introduced in the next Finance Bill to widen the circumstances in which companies can calculate their taxable profits in a currency other than sterling. The new rules will apply to accounting periods beginning on or after January 1 2000.

Dividends received by a Finnish company on direct foreign investment are generally exempt from tax. If the Finnish company has distributed the dividend received from a foreign country to its foreign owners, it may previously have been subject to a supplementary tax. As a result, income received from another country may also have been taxed at a corporate tax rate in Finland.

Eugen Bogenschütz and Kelly Wright of Haarmann, Hemmelrath & Partner, Frankfurt-am-Main analyze the structure and outcome of the 1998 Daimler-Chrysler merger

Under two recent advance rulings, foreign investors in India may be subject to amendments to the Finance Act, designed to prevent Indian companies taking undue advantage of certain concessions. Keyur Shah, Arthur Andersen, Mumbai reports

The IRS has issued new regulations that further limit the use of check-the-box tax planning techniques used by US companies for their foreign subsidiaries. Keith Martin of Chadbourne & Parke assesses the extent of the new restrictions

Spanish value-added tax (VAT) law makes the exercise of the right to deduct VAT borne before starting up activities conditional on the fulfillment of certain requirements (a formal pre-commencement of activities declaration must be filed: in practice, those activities charging VAT must be commenced within one year, or an application must be filed to extend such term). Failure to meet those requirements means a deferral of the VAT deduction until activities are actually started, and a consequent financial cost.

The £114 billion ($XX) agreement will create the world's largest pharmaceuticals group, with combined annual sales of more than £15 billion. The new company, Glaxo SmithKline, will control 7.3% of the world's drugs market. Glaxo shareholders will receive 58.75% of the new company's share capital, with SmithKline taking 41.25%.

Many Canadian non-residents with no permanent establishment in Canada might well anticipate that remuneration for services rendered in Canada should not be subject to withholding tax. The federal authorities do not agree and require a 15% withholding on fees, commissions or other amounts paid to a non-resident in respect of services rendered within Canada. (A further 9% Quebec withholding is required in respect of non-resident services rendered in that province.) If the non-resident is not subject to Canadian tax, they must apply for a refund by filing a Canadian tax return. If the non-resident is subject to Canadian taxation, the withheld amount can be applied to the non-resident's Canadian tax liability.

At present, in Ireland, there is a difference in the tax treatment of unit-linked investment products in the form of life assurance policies or mutual funds, dependant on whether they are available to Irish residents (Domestic Funds) or are exclusively available to non-residents (IFSC Funds). In the International Financial Services Centre (IFSC) where such products are sold exclusively to non-Irish residents, both the fund itself and the policy holders are exempt from Irish tax. In the case of such products outside the IFSC, however, Irish residents may be unitholders and the fund is subject to tax on an ongoing basis at the standard income tax rate of 24% (22% from April 6 2000).