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Changes to Japan’s debt securities regime have cleared the way for withholding tax exemption. Yusaku Ono of Hamada & Matsumoto, Tokyo advises on how non-residents and non-Japanese corporations can make the most of the new system

Sweden has attempted several versions of a GAAR. However, the latest version still leaves taxpayers uncertain that it will be applied to their transactions. By Brita Munck-Persson and Thomas Lakhall, Mannheimer Swartling Advokatbyrå, Stockholm

The 52nd IFA Congress, held in October this year, sported a new style. But was the substance and quality of debate enhanced? Phillippa Cannon sifts through the discussions to identify key questions and, in some places, even conclusions

Taxpayers who believe that their transactions are too complex for the revenue authorities to sort out should pay very close attention to recent IRS victories in the US courts. By Keith Martin, Chadbourne & Parke, Washington DC

A bill has been submitted to the Netherlands parliament on the issue of the tax consequences of the introduction of the euro.

In a decision dated April 30 1997, but published considerably later, the Tax Court of Rheinland-Pfalz has held that the income of a foreign satellite operator from a "transponder usage agreement" with a German provider of television programming was not subject to taxation in Germany.

On May 31 1996 a new double taxation convention between Austria and the US was signed. Following exchange of instruments of ratification on December 19 1997, the convention entered into force on February 1 1998. Under article 28, its provisions allocating taxation rights will have effect in respect of taxes withheld at source, for amounts paid or credited on or after April 1 1998.

Allegiance Corporation, a US distributor of health care products and provider of cost management services, is to merge with Cardinal Health, a pharmaceutical services company. The merger will create a health care products and services company worth around $21 billion. Allegiance shareholders will receive 0.415 Cardinal Health common shares for each share of Allegiance common stock owned. Cardinal Health will issue approximately 49 million fully diluted shares. The combination has been structured as a tax-free transaction, and will be accounted for as a pooling of interests. Davis Polk & Wardwell in New York advised Allegiance Corporation. The tax team included partner Dana Trier and associate Jonathan Bennett.

Kingfisher, the UK retail group, is to merge its UK business B&Q with Castorama of France. The deal will create Europe's largest home improvement chain with annual sales of around $6.79 billion. Kingfisher will exchange 100% of B&Q shares for a 54.6% stake in the fully-diluted equity of an enlarged Castorama. Advice to Kingfisher came from law firm Freshfields in London and Paris. The tax team included partner Roger Berner and manager Kate Habershon in London, and partner James Naudoyer in Paris. Castorama was advised by Gouldens. The tax partner involved was Blaise Marin.

Australia's Liberal Party was reelected on October 3 1998. Its pre-election tax reform package will now be implemented, some key aspects of which follow.