ITR Search | International Tax Review

The vis attractiva

The use of the so-called vis attractiva (literally power of attraction) highlights the link between the concepts of income and residence. It might be used to attribute foreign income profits to substantially Italian tax resident individuals who are formally resident abroad.

March 01 1999

Vienna-Tax Reform Commission proposes new legislation for 2000

The Austrian government is planning to reform various aspects of the Austrian tax system as of January 1 2000. The Ministry of Finance had requested the formation of a Tax Reform Commission, consisting of representatives of various public bodies, to prepare a proposal for the tax reform programme. The commission issued its report in November 1998, which covered the following issues:

March 01 1999

Linklaters in mobile phone contract

UK firm Linklaters is advising Vodafone on its $63 billion acquisition of US telecommunications company Airtouch.

March 01 1999

When it pays to talk to the taxman

Revenue authorities are keen to appear to be as open as possible and to consult business when preparing major legislation. But how beneficial is consultation? Rosie Murray West asks whether the words are falling on deaf ears

March 01 1999

Thommessen, Krefting hammers out metal buy

French state-owned company Eramet SA has bought 25% of the Norwegian metals company Elkem. The transaction is worth $204 million. Eramet will control two of Elkem’s magnesium smelting plants. The transaction was conducted under English law, and so involved law firms across four jurisdictions.

March 01 1999

UK moves to close M&A tax loophole

The UK Inland Revenue has acted to close what it sees as a loophole in tax law that allows companies involved in international mergers and acquisitions to avoid a 1.5% tax. A number of recent transactions, including the BP/Amoco merger, the Astra/Zeneca merger and the Vodafone/Airtouch deal, were structured to benefit from an exemption which allowed the companies to avoid the 1.5% stamp duty reserve tax.

March 01 1999

News in Brief

Bond market fails to win exemption, Manx Treasury reveals 15% company tax, Indonesia gives tax breaks to revive economy, Loss of revenue reveals Japanese troubles

March 01 1999

Pünder’s loss to Shearman signals tough times ahead

German law firm Pünder Volhard Weber & Axter has paid a high price for the breakdown of its international network, losing four tax lawyers and three other tax professionals to US firm Shearman & Sterling.

March 01 1999

Back to the drawing board for Canada?

Proposals to reform Canada’s interest imputation rule have provoked debate. Elinore Richardson and Angelo Nikolakakis of Stikeman, Elliott, Montreal and Toronto examine the proposals and outline the arguments against their unqualified adoption

March 01 1999

Clinton stuns with tough budget

Bill Clinton’s latest budget includes numerous international tax proposals and tax shelter provisions. Hal Hicks, David Benson, Margie Rollinson, and Peg O’Connor of Ernst & Young in Washington DC analyze the budget, and explain court and treaty developments

March 01 1999

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