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The US Internal Revenue Service (IRS) announced on January 16 1998 that it will clamp down on the use of hybrid branches that simultaneously reduce foreign tax and defer US tax. A number of US power companies engaged in overseas power projects use these entities. Offshore holding companies are formed for foreign investment, and the payment of US tax is deferred until earnings have been repatriated to the US. Since January 1997, US companies could check the box to ensure that foreign entities, with a single owner, were treated as transparent for US tax purposes.

The first budget statement delivered on December 3 1997 by the new minister for finance, Charlie McCreevy, was also the first budget to be delivered before the start of the financial year. The minister used the opportunity presented by very high economic growth rates, and the resulting tax buoyancy, to make a number of significant tax changes. The minister has confirmed that with effect from January 1 2006, the standard corporation tax rate applicable to the trading profits of non-manufacturing companies (including financial services companies operating in the Dublin docks area whose 10% tax rate expires on that date) will be 12.5%. A higher rate of 25% will apply to the non-trading income of those companies. Manufacturing companies will continue to benefit from the lower 10% manufacturing tax rate until it expires at the end of 2010.

Reed Elsevier is to dispose of its consumer magazine group IPC in a deal worth £860 million ($1.38 billion). The purchasing MBO group is financed by Cinven, with debt underwritten by Goldman Sachs. Freshfields acted for Reed Elsevier, with tax advice from partner Colin Hargreaves and manager Isabel de May.

In 1997, a number of high-profile tax advisers made a bid for professional independence by setting up their own tax boutiques. Can these firms survive without the support of a large law or accounting firm network? Phillippa Cannon reports

US carpet manufacturer Interface has bought the European carpet division of UK company Readicut International for $50.3 million. Readicut was advised by UK law firm Eversheds with tax advice from partner Richard Hutchinson in Leeds.

UK brewer Bass has disposed of Coral Bookmakers to fellow bookmakers Ladbrokes. The deal is worth approximately £375.5 million ($604 million). Bass was advised by tax partner Charles Hellier at Linklaters in London.

Directive 69/335/EEC — Contribution of immovable property.

Directive 69/335/EEC — Regional charge on vehicle registration certificates.

Directive 69/335/EEC — Registration charges on companies — Procedural time-limits under national law.

International business in New Zealand needs to sit up and take notice of new transfer pricing guidelines, issued in October 1997. The guidelines highlight pitfalls for the unwary in New Zealand’s legislation. By Christina Rich, Price Waterhouse, Auckland