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A recent ruling means that non-resident companies with a permanent establishment in India must now comply with the country’s minimum alternative tax policy. Jignesh R Shah, Price Waterhouse & Co, Mumbai analyzes the case and its implications

Self-assessment for transfer pricing exposes taxpayers to several potential risks. In this context an effective APA system is vital. Robert Cole, Alston & Bird, Washington DC and Michael McGowan of Allen & Overy, London outline their recommendations.

An OECD conference has laid the foundations for the taxation of electronic commerce. The conference, entitled: ?A Borderless World; Realizing the Potential of Global Electronic Commerce? was held in Ottawa, Canada. It was attended by nearly one thousand representatives from government, business and consumer groups. The meeting aimed to promote greater international policy compatibility on electronic commerce. The conference reaffirmed five major principles for the taxation of electronic commerce: neutrality, efficiency, certainty, fairness and flexibility.

First Active, the Irish building society, is to be floated on the London and Dublin stock exchanges. The market capitalization is expected to reach IR£510 million ($710 million). First Active is raising IR£104 million new capital to fund expansion. The building society has operations in Ireland, Northern Ireland, the UK and Guernsey. Arthur Andersen in Dublin provided tax advice on the Irish aspects of the flotation. The tax partner involved was Sharon Burke. Tax managers were Maireod Foley and Frank O'Neill. Advice in Dublin also came from PricewaterhouseCoopers and law firm Arthur Cox.

A non-resident income tax law is expected to come into force in Spain effective January 1 1999.

Bain Capital, the US investment company, has bought Domino Pizza from the company's founder Thomas Monaghan. The deal is worth approximately $1 billion. Bain will acquire a 90% stake in Domino. Monaghan will retain an equity interest in Domino and will serve as its non-executive chairman. Domino is the world's largest pizza company with annual sales of $3.1 billion. Advice to Bain Capital came from Ropes & Gray in Boston. The tax partners involved were Eric Elfman and Carolyn Osteer. The tax associate was Susan Morse.

A consortium including Prudential Insurance Company of America and the Abu Dhabi Investment Authority has bought British Aerospace's property development business, Arlington Securities. The sale is valued at £285 million ($450 million). Cameron McKenna in London advised Prudential Insurance Company of America. The tax team included partner Stephan Charge and assistant Charles Elphicke.

Dutch retail groups Vendex and KBB are to merge in a deal valued at Fls1.91 bn ($1 billion). The Dutch authorities have given the go ahead to the deal without it being subject to special conditions. The new groups will control almost all department stores in the Netherlands. Tax advice to Vendex came from KPMG Meijberg in Amsterdam. The tax partners involved were Adri van Kemenade and Wytze van der Meer. Vendex is also represented by Loeff Claeys Verbeke in Amsterdam

German property group Deutsche Gesellschaft fur Immobilienfonds (DEGI) has sold eight properties in central London to UK group Heron International. The deal is valued at £205 million ($350 million) Advice to DEGI came from London law firm Nabarro Nathanson. Senior associate Lydia Simpson handled the tax matters.

New York-based tax litigator Lawrence Hill has joined White and Case as a partner. Previously, he was head of tax litigation and Internal Revenue Service controversy at Brown & Wood. Hill plays an active role as an advocate for the accounting profession and represents a number of big five firms. Specialities include advising accountants on ethical and risk management issues. He has also represented banking and investment banking companies in tax and litigation matters.