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  • The tax issues of structuring inbound and outbound expatriate contracts in Hong Kong centre on the test of location of employment. Ian Love, PricewaterhouseCoopers, Hong Kong sets out the pitfalls and opportunities to be addressed
  • The permanent establishment concept is central to the taxation of businesses operating in more than one country. But the structures used have moved on since the original 1963 OECD definition. Oliver Ralph examines the pressing need for a reformulation
  • As the world moves towards possible recession, International Tax Review reveals the big five revenue figures for 1998. Rosie Murray-West talks to the global heads of tax and asks them how they prosper in the face of adversity
  • Foreign investors in Japan face myriad options in their search for tax-efficient flow-through structures. Dean A Yoost and Richard Elliott of PricewaterhouseCoopers, Tokyo explore the possibilities
  • The UK Inland Revenue has released proposals for an advance pricing agreement (APA) system. The proposals come as part of the general review of transfer pricing which was announced in the March 1998 budget.
  • Both the US Treasury Department and the UK Inland Revenue have announced that they will schedule meetings early next year for the purpose of renegotiating the existing income tax treaty, which has been in effect since 1975.
  • From: Steve Towers Partner, Deloitte Touche Tohmatsu, Melbourne, Australia.
  • Following in the footsteps of its competitor Arthur Andersen, which in 1997 merged with Spanish law firm J&A Garrigues, PricewaterhouseCoopers has announced a merger with the Madrid office of Spanish law firm Mullerat & Roca. "The system of Garrigues & Andersen is the right way to increase our presence in the legal market," says Antonio Lewis Vañon, head of the legal practice at PricewaterhouseCoopers.
  • The London branch of The Sumitomo Bank, Limited completed its Aurora corporate loan securitization in April 1998. Many corporate loan securitizations (otherwise known as collateralized loan obligations, or CLOs) involve complicated structures.
  • Skadden, Arps, Slate, Meagher and Flom is assisting internet service provider America Online in its acquisition of Netscape.