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Whether a duty imposed on the capitalisation of undistributed, but previously taxed, profits of a capital company constitutes a capital duty prohibited by Council Directive 69/335/EEC, as amended by Council Directive 85/303/EEC.

The Austrian Tax Reform Act 2000 has passed the legislation process in the Austrian parliament.

The recent controversy surrounding the taxation of relevant discount securities in the UK has produced a situation similar to that which applied in 1996. Sarah Squires of Cadwalader, Wickersham & Taft in London asks if the months of debate were really necessary

When Japan lifted its restriction on holding companies last year, it opened up a range of possibilities. Dean Yoost of PricewaterhouseCoopers and Masaakira Kitazawa of Anderson Mori advise on how to avoid the pitfalls and make the most of the new opportunities

UK firm Ashurst Morris Crisp is advising Deutsche Telecom on its purchase of UK mobile phone operator One2One. Deutsche will pay Cable & Wireless and MediaOne (who each have a 50% stake in the operator) £8.4 billion ($13.5 billion) including debt, for the purchase.

On July 9 1999, the Treasury formally withdrew the proposed and temporary regulations issued on March 23 1998, relating to the use of hybrid branch entities to avoid subpart F income. At the same time, the Treasury issued new proposed regulations on the treatment of hybrid branch transactions. The Treasury also officially withdrew the proposed regulations relating to the treatment of foreign partnerships for purposes of subpart F (Brown Group regulations) but did not issue any new regulations in their place. New regulations regarding the treatment of a controlled foreign corporation's (CFC) distributive share of partnership income will be proposed at a later date.

The Irish tax authorities have recently published details of the revised tax arrangements to apply to stock lending and repurchase (repo) transactions. Stock lending and repo transactions involve the temporary transfer of stock or securities from one party to another with the simultaneous commitment to reverse the transaction at some point in the future. From a tax perspective, there are two important aspects to stock lending and repo transactions.

The Tax Relief Act for the Years 1999, 2000, and 2002 introduced a new income tax withholding provision for payments made to foreign contractors. The new rules came into effect on April 1 1999 and require domestic and foreign persons to withhold 25% of the gross amount of payments made from this date to foreign contractors for a wide range of work performed in Germany or perhaps simply used there. While the problem which provoked the new withholding rules involved non-compliance by foreign construction firms with their German tax obligations, the withholding provision actually enacted applies to all sectors of the economy and can include purely intellectual work such as that of architects, engineers, or attorneys as well.

The Committee of Fiscal Affairs of the OECD has acted quickly to diffuse a potential row between itself and the BIAC (Business and Industry Advisory Committee) over last year’s report on harmful tax competition.

Canadian law firm Stikeman Elliott is advising British American Tobacco (BAT) on its offer to acquire Imasco, the Canadian consumer products group. BAT already owns 42% of Imasco, but is offering to buy the remaining equity for around C$ 10.3 billion ($6.9 billion). If the deal goes ahead BAT will keep Imperial Tobacco, Imasco’s tobacco business, but sell the group’s other subsidiaries.