ITR Search | International Tax Review

Non-discrimination

A recent advance ruling discussed the ambit of the non-discrimination clause in Article 26 of the Double Taxation Avoidance Agreement between India and France (DTAA). The issue was whether the applicant (a non-resident French Banking Company, operating through a branch office in India) could use lower tax rates as applicable to a domestic company (as against the higher rates applicable to a non-domestic foreign company).

April 30 1999

Indian courts limit treaty benefits

Multinationals operating in India have recently used treaties to challenge the application of different tax rates to domestic and foreign companies. Jignesh R Shah of PricewaterhouseCoopers, Mumbai analyses the court decisions and their consequences

April 30 1999

Hale & Dorr in real-estate merger

Hale & Dorr in Boston is representing real-estate firm Berkshire Realty in its merger with management group Brekshire Realty Holdings. The transaction is valued at $1.3 billion. Realty Holdings is a partnership formed by chairman Douglas Krupp, affiliates of Blackstone Real Estate Advisors and Whitehall Street Real Estate Limited Partnership XI (an affiliate of Goldman Sachs & Co.)

April 30 1999

Accounting Act and Joint Stock Companies Acts

A new Accounting Act and two Joint Stock Companies Acts were introduced with effect from January 1 1999. These may have some effect for the companies tax position, and distribution capacity.

April 30 1999

Firms expand to conquer Asia

For true regional coverage to be more than a slogan, advisers in Asia have some hard work to do. There are still many gaps in even the most extensive networks. But, as Oliver Ralph and Rosie Murray-West discover, clients want coverage that mirrors their own plans

April 30 1999

Austrian Government agrees tax reform 2000

On March 23 1999 the Austrian coalition. government reached political agreement on the essence of the tax reform for 2000. The following text introduces the subject and takes into account the opinion of the Federal Ministry of Finance on how to implement the political agreement.

April 30 1999

Launch of Ecological Taxation in Germany

The energy tax increases contained in the new tax legislation (see International Tax Review April 1999) potentially represent more than just a rise in existing excise taxes and, in the case of electricity, the introduction of a new one. In the eyes of their proponents, they are the start of an ambitious programme of ecological tax reform.

April 30 1999

US eyes international overhaul

The US Congress has found that foreign multinationals may have an unfair advantage in the international tax market. Hal Hicks, David Benson and Marjorie Rollinson of Ernst & Young, Washington examine the prospects for change and possible amendments to tax shelter rules

April 30 1999

PwC and Anderson fight it out in Austrailia

The announcement that Tony Rumble, a Finance and Treasury taxation specialist, has joined PricewaterhouseCoopers as a partner, has provoked strong reactions from Arthur Andersen, where Rumble had been working on a six month contract.

April 30 1999

Sullivan and Cromwell in Arco/Amoco deal

US firm Sullivan and Cromwell are advising BP Amoco on the takeover of the Atlantic Richfield Company (Arco). The acquisition will be made through a stock swap and is valued at $26.8 billion. The combined company will have a market capitilization of arounds $190 billion. Tax partner Willard Taylor, from Sullivan and Cromwell’s New York office, worked on the deal for BP Amoco.

April 30 1999

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