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A comparative approach is adopted in this assessment of Italy’s realistic potential as a holding company location. By Piergiorgio Valente and Marco Magenta, Studio Associato Legale Tributario (associated with Ernst & Young International), Milan

ICI has taken its case for consortium relief to the European Court of Justice. The Advocate-General’s opinion may not satisfy ICI, but it does imply the liberalization of consortium relief for EU businesses. By Murray Clayson of Freshfields, London

The Advocate-General has issued his opinion in the ICI v Colmer case before the European Court. The issue was whether a consortium company with EU trading subsidiaries (as opposed to wholly or mainly UK subsidiaries) would qualify under provisions allowing surrender of losses. The House of Lords in the UK had ruled that EU companies did not qualify under the UK legislation.

Octav Botner, founder of Nissan UK, has issued a writ against the Inland Revenue for malicious prosecution. The writ also names two former Inland Revenue inspectors; Robert Brown, now with Ernst & Young and John Cawdron, now with Price Waterhouse.

Canadian National Railways has announced a $3 billion strategic merger with Illinois Central.

The US Internal Revenue Service has signalled its intention to limit the tax advantages available to some hybrid branches. Joseph DeCarlo of Price Waterhouse LLP, and Alan Granwell and Dirk Suringa of Ivins, Phillips & Barker, Washington DC report

For the first time, Deloitte Touche Tohmatsu has released its worldwide tax fee income results.

An international group of investigators is said to be examining the tax affairs of global media group News Corporation. The rumoured investigation is thought to involve senior tax investigators from tax authorities in the UK, US, Australia and Canada. A spokesman for the UK's Inland Revenue would neither confirm nor deny the story, adding that the affairs of individual companies are never discussed. However a prominent international tax lawyer has told International Tax Review that even if there is as yet no investigation, the adverse publicity will probably ensure one.

Scottish Equitable has disposed of Aegon Financial Services Group to the UK's Life Assurance Holding Corporation for an undisclosed sum.

EC Tax Law