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  • BTP, the UK-based chemicals group, is to buy Italian chemicals company Archimica for £100 million ($160 million). The deal will take BTP into making active ingredients for pharmaceuticals companies. Archimica specializes in anti-AIDS and antibiotic molecules. BTP was advised by Ashurst Morris Crisp in London. Tax partner Richard Palmer worked on the deal. Negri Clementi Montironi & Soci in Milan also worked with BTP.
  • As part of the move to bring the controlled foreign corporation (CFC) legislation within corporation tax self- assessment, the UK Inland Revenue has announced that the excluded countries list exemption is to be brought within regulations so that in future UK companies will have a legal basis for relying on it.
  • France and Switzerland have signed a new protocol to the existing income tax treaty of 1966/1969, which entered into force on August 1 1998. The major changes are outlined below. Nevertheless there is still uncertainty as to whether the protocol will have an impact on the Swiss branches of French companies in regard to the French anti-abuse legislation. This point is still being discussed.
  • The Irish government has formally announced the new corporate tax regime for Ireland, which has been agreed with the EU Commission.
  • Financial authorities in Austria and Germany have continued negotiations over the new double tax treaty of May 1998. Representatives of the Austrian Ministry of Finance have already disclosed the most important changes to the existing double tax treaty that the authorities were able to agree on. Although the negotiations have not yet been finalized in all aspects, it is likely that the following changes will be effective from the tax year 2000.
  • Capital gains on the repayment to non-residents of units in Spanish mutual funds are taxed at 35%, unless the non-resident in question is protected by a tax treaty or is an EU resident, in which case the capital gain will be tax exempt.
  • A ruling of the Brandenburg tax court raises interesting issues concerning the value-added tax (VAT) treatment of companies which have little substance and engage in no meaningful economic activity.
  • Right of establishment — Corporation tax — Surrender by one company to another company in the same group of tax relief on trading losses — Residence requirement imposed on group companies — Discrimination according to the place of the corporate seat— Obligations of the national court.
  • Pearson, the UK-based media group, has agreed to acquire publishing company Simon & Schuster from US group Viacom. The deal is valued at £2.75 billion ($4.6 billion). Following the purchase, Pearson will sell certain parts of Simon & Schuster to US leveraged buy-out company Hicks, Muse, Tate & Furst.
  • TI Group, a UK fluid technology and aerospace group, has made a £267 million ($427 million) bid for EIS Group, a UK marine engineering company.