Search results for

Right of establishment — Corporation tax — Surrender by one company to another company in the same group of tax relief on trading losses — Residence requirement imposed on group companies — Discrimination according to the place of the corporate seat— Obligations of the national court.

Pearson, the UK-based media group, has agreed to acquire publishing company Simon & Schuster from US group Viacom. The deal is valued at £2.75 billion ($4.6 billion). Following the purchase, Pearson will sell certain parts of Simon & Schuster to US leveraged buy-out company Hicks, Muse, Tate & Furst.

TI Group, a UK fluid technology and aerospace group, has made a £267 million ($427 million) bid for EIS Group, a UK marine engineering company.

In the case of qualifying pension plans, the contribution of the employer under the scheme is not taxable, whereas the contribution of the employee is tax deductible. Benefits received from a qualifying plan are in general fully subject to Netherlands income tax. Special rules provide for taxation over the economic value of an employee's pension rights in case of certain "forbidden" transactions.

Artemis of France is to buy UK auction house Christies for £721 million ($1.1 billion).

In March of this year, the German Parliament and Federal Council ratified two major pieces of legislation which have since taken effect. The Law on Corporate Control and Transparency makes extensive changes to the provisions of the Stock Corporation Act (Aktiengesetz) to improve corporate accountability. This bill also liberalizes the provisions relating to the issuance of stock options to senior executives and other employees. Some of the new provisions may be applicable by analogy to limited liability companies. Most provisions either take immediate effect or apply to fiscal years beginning 1999 onwards.

The IRS has updated its definition of financial products, extending a safe harbour for securities and commodities to derivatives. Linda Carlisle and Daniel Gilroy of White & Case, Washington DC, report on regulations which could lead to a boom in hedge funds

Jefferson Smurfit Corporation of St. Louis, US is to merge with Stone Container of Chicago. The merger is worth approximately $2 billion and will create one of the world's largest paperboard and paper packaging companies. It will be known as Smurfit-Stone Container Corporation and will be worth approximately $11 billion.

Since the early 1990s, non-resident corporate income taxpayers in Spain have benefitted from important domestic law exemptions pertaining to different types of income from Spanish sources.

US paint maker PPG Industries has agreed to purchase two coatings businesses from UK chemicals company Courtaulds. The deal is worth approximately £200 million ($320 million). PPG had been bidding against Dutch group Akzo Nobel for control of the whole of Courtaulds. Akzo Nobel is now expected to take control of the remaining areas of Courtauld's businesses (see International Tax Review June 1998, page 6).