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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.

Australia signed a Double Tax Agreement (DTA) with South Africa on July 1 1999 and a Protocol amending the Malaysian DTA on August 2 1999. The DTAs are not yet in force.

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.

The American Bar Association has rejected plans to allow lawyers to practise in multidisciplinary partnerships. A meeting of the policymaking body, the House of Delegates, voted by 304-98 to replace a report that would have eased restrictions on MDPs.

Fried Frank Harris Shriver & Jacobson is advising Procter & Gamble (P&G) on the acquisition of Iams, a petfood company for about $2.3 billion. The deal is subject to regulatory approval but should be complete within a month.

International Tax Review’s annual survey finds the big five continuing to dominate. But our results also find that corporate tax work is growing rapidly, and that there is plenty of room for all to prosper. Rosie Murray-West and Oliver Ralph ask why demand is expanding so quickly

Internal taxation — Tax deduction — Expenditure on research — Proprietary medicinal products.

Interest expenses are, as a rule, fully deductible for Norwegian corporations. However, the right to deductions for Norwegian resident taxpayers owning real property abroad is subject to limitations, in the way that interest expenses equivalent to the pro rata share of the taxpayer's gross real property situated abroad are disallowed. This treatment may now change. The Ministry of Finance is considering new rules under which all interest expenses are deductible to the extent the expenses does not relate to income exempt from Norwegian taxation under a double tax treaty.

Ask a tax professional about the major tax advice developments of the last 12 months and the answers will highlight the firm’s success. Ask a client and a different story emerges. Rosie Murray-West asks corporate tax directors about their loves and hates