International Tax News.

Transcription

1 International Tax News. Contents June/July 2003 Highlights of this edition of International Tax News include: Further developments in Belgium with regard to Coordination Centres (page 4). An important decision on the application of Luxembourg tax treaties to branches (page 6). Proposed anti-avoidance rules in Spain aimed at tax-driven artificial structures (page 10). EU Savings Directive and Interest and Royalties Directive adopted (page 12). Belgium 4 Italy 5 Luxembourg 6 Poland 7 Russia 8 Spain 10 Sweden 11 UK 11 US 12 EU July

2 The full list of items in this edition s International Tax News is: Belgium Linklaters success in the Belgian Government s application to the ECJ on the Coordination Centre regime in which Linklaters acted for the Belgian Government (page 4) Withholding tax regulations as applied to interest payments: new changes (page 5) Italy A report from Italy on Tax Grouping rules (page 5) Luxembourg Our Luxembourg office reports on an interesting decision on the application of Luxembourg s tax treaties to Luxembourg branches (page 6) Poland Recent developments in Poland are discussed by our Warsaw office. New VAT law creates controversy (page 7) German Showdown with Polish tax authorities (page 7) Revenues obtained in the territory of the Republic of Poland (page 8) Russia Our Moscow office reports on the Russian Tax Authority s recommendation affecting all Russian Tax Treaties (page 8) Spain Our Madird office reports on new anti avoidance provisions Conflict in the application of tax law (page 10) Procedure (page 10) Implications (page 10) Sweden Our Swedish office reports on the Swedish CFC situation rules (page 11) 2 June/July 2003

3 UK Recent developments from our London office: Loss Relief Group Litigation (page 11) Tax and the City of London (page 11) Finance Act 2003 (page 11) Deutsche Morgan Grenfell plc v CIR and HM Attorney General (page 12) US Our New York office reports on a new Act which includes reductions in the tax rates on capital gains and dividends (page 12) EU A round up of developments from the Commission and the European Court of Justice. EU Savings Directive and Interest and Royalties Directive (page 12) Negotiation of Tax Treaties (page 13) VAT: Public Consultation on place of taxation of the supply of services (page 13) Investment Fund Discrimination: Germany and Austria (page 13) Pensions taxation Infringement Procedures: Denmark, UK and Ireland (page 14) Consultations (page 14) C-422/01 Försäkringsaktiebolaget Skandia (publ), Ola Ramstedt v Riksskatteverket C-305/01, Finanzamt Groß-Gerau v MKG-Kraftfahrzeuge-Factory GmbH (page 15) C-442/01, KapHag Renditefonds 35 Spreecenter Berlin-Hellersdorf 3. Tranche GbR v Finanzamt Charlottenburg (page 15) International Tax News. 3

4 Belgium Our Brussels Office reports on: Linklaters success in the Belgian Government s application to the ECJ on the Coodination Centre regime in which Linklaters acted for the Belgian Government. Withholding tax regulations as applied to interest payments: new changes. ECJ Success: Coordination Centres In the April/May 2003 issue of Linklaters' International Tax News, we reported on the ongoing proceedings within the EU institutions with regard to the Belgian coordination centre regime. The first proceedings took place within the framework of the Code of Conduct for business taxation which was formally approved by the European Council on 3 June It provides for the gradual roll-back and end or modification to a list 66 'harmful' measures including Belgian coordination centres. Under this Code of conduct, coordination centres can continue benefiting from the existing regime until the end of Furthermore, centres which had been recognised on 31 December 2000 can live out the remainder of their ongoing 10-year recognition decree until 31 December 2010 at the latest. In addition, the Code of Conduct also approved the new coordination centre regime which had been enacted by the Law of 24 December A State aid investigation regarding this new regime is still ongoing. Regarding the second proceedings, i.e. the State Aid investigation led by the European Commission against the existing regime, we had last reported that the European Commission decided to refuse the Belgian authorities the possibility of granting any renewals. Belgium filed an appeal before the Court of Justice in order to obtain the same transition period as had been granted under the Code of Conduct. On 26 June 2003, the President of the European Court of Justice rendered a preliminary decision suspending, until a final decision is reached by the Court, the Commission's refusal to allow renewals under the existing regime. Such renewals for centres whose recognition decree expires in the coming months and years should now be possible. Because of Belgium's commitment under the Code of Conduct, it is expected that renewals will only be granted until the end of The last issue which remains is for the centres to obtain the assurance that no reclaim will be requested from them for the tax advantages they will have received if ever the final decision of the Court is negative. Discussions on this issue with the Commission are ongoing and it is expected that Belgium will obtain the assurance that no such reclaim will be requested. 4 June/July 2003

5 Linklaters acted for the Belgian Government before the ECJ. New rules on interest withholding tax exemptions The note below summarises certain modifications to Belgian tax rules introduced regarding interest withholding tax exemptions, including (i) the explicit qualification of certain holding companies as financial institutions, (ii) extension of such exemptions to coordination centers and other in-house banks, and (iii) the abolition of the exemption from withholding tax on interest income from real estate certificates. Italy A report from Italy on Tax Grouping Rules. Group taxation in Italy under present and future legislation The Italian Tax Authorities have recently issued a ruling.on VAT group taxation in cases of mergers involving the parent company of the group. There are different definitions of a group depending on the kind of taxes involved. Current status of the law VAT: the Parent Company is entitled to centralise the VAT obligations and payments of all its controlled companies (the Controlled Companies ). For such purposes, a company is considered as a Controlled Company provided that the parent company owns, directly or indirectly, more than 50% of its stated capital since January 1 of the preceding fiscal year. The VAT group legislation has both operational and financial advantages, since it allows the Parent Company to offset VAT credit balances against VAT debit balances among the group companies, on a monthly basis. In this regard, the Italian Tax Authorities have confirmed in the Ruling that, where the Parent Company is merged into another company, the surviving company would inherit the rights and obligations of the Parent Company related to VAT group taxation (and, in particular, the holding period of the participation in the Controlled Companies) by operation of law. VAT group taxation will not be affected by the tax reform law recently enacted by the Italian Parliament ( Tax Reform Law, which was covered in International Tax News April/May 2003). International Tax News. 5

6 Corporate income tax: no group taxation is presently allowed for corporate income tax ( IRPEG ) purposes. Pursuant to the Tax Reform Law, group taxation is expected to be introduced starting from January 1, In particular, group companies will be entitled to elect for the consolidation of their taxable income for the purposes of the new 33% corporate income tax (which will replace IRPEG), which will be subject to tax in the hands of their Italian parent company. Group taxation will apply with different rules with respect to Italian group companies and foreign group companies. Local tax: no group taxation is presently allowed for local tax ( IRAP ) purposes, neither it is provided in the Tax Reform Law. However, it is to be considered pursuant to the Tax Reform Law, that IRAP shall be progressively repealed and phased out (possibly, in 2006). Future changes After implementation of the Tax Reform Law, group taxation will be available for both VAT and corporate income tax purposes, which may represent a significant advantage for company groups. However, the fact that no group taxation will be provided for IRAP purposes seems to represent an inconsistency and is likely to cause inconvenience, at least until IRAP is definitively repealed. Massimo Agostini (Milan; MAgostini@gop.it;) Claudia Gregori (Rome; (CGregori@gop.it) Luxembourg Our Luxembourg Office reports on an interesting decision on the application of Luxembourg s tax treaties to Luxembourg branches The Luxembourg Tax Court ( Tribunal administratif ) decided on 29 April 2003 that a Luxembourg branch of a German company could benefit from the provisions of the Luxembourg-Spain double taxation treaty. This case confirmed that the Luxembourg branch of a German company might benefit from fictitious tax credits derived from bonds issued by Spanish public entities. Under the traditional analysis made in Luxembourg, only resident taxpayers were entitled to invoke the benefits of the double taxation treaties concluded by Luxembourg. This case overruled this position by deciding that the Luxembourg branch of a EU company should be treated in the same way as a resident taxpayer. 6 June/July 2003

7 The legal grounds invoked were the freedom of establishment of Article 43 of the EC Treaty, together with the decision of the European Court of Justice of 21 September 1999 Compagnie de Saint-Gobain, Zweigniederlassung Deutschland c/ Finanzamt Aachen-Innenstadt. This decision has been interpreted by the Luxembourg Tax Court as transposing the principle of equal tax treatment between permanent establishments and principal establishments within the EU to the scope of the double taxation treaties. The Luxembourg Tax Court did not proceed through the mechanism of the preliminary question before the European Court of Justice. This precedent relating to the offsetting of fictitious foreign tax credits may, in principle, be extended to any treaty benefits granted by double taxation treaties concluded by Luxembourg with other EU countries. This decision may create an interesting precedent for EU investors which do not have a Luxembourg subsidiary, in view of the extensive treaty network of Luxembourg and the attractiveness of the tax rules applicable in the Grand- Duchy. Poland Recent developments in Poland are discussed by our Warsaw Office New VAT law creates controversy The new law on VAT is meant to adapt Polish regulations to EU standards. The Polish government is nearing the end of consultations on the draft law, and the draft could be passed to the Parliament soon. So far, the new law has raised same controversial issues. It has been suggested that the draft law is an imperfect translation of the EU directive. For example, definitions used in the draft law are inconsistent, which could lead to conflicts between the tax authorities and the taxpayers. The law also introduces many unnecessary formalities, such as the creation of a separate register of taxpayers maintaining trade relations with countries of the EU. Because of these issues, the new law could be subject to review by the Constitutional Tribunal. German showdown with Polish tax authorities The problem relates to dividends, interests or royalties. Under domestic law, the former is subject to 15% and the latter two subject to 20% withholding tax. The new Polish-German double tax treaty decreases the withholding tax to 5%. Under the treaty, if the local tax regulations stipulate a higher rate the tax authorities may demand the payment calculated under local International Tax News. 7

8 regulations. The tax authorities may, on the basis of request filed by the foreign entity, then refund any overpaid tax. This result in negative cash flow for German companies, as for a certain period of time overpaid tax will be frozen in the Polish tax offices bank accounts. Revenues obtained in the territory of the Republic of Poland In its judgment dated 9 November 2001, the Supreme Administrative Court explained the meaning of the concept revenue obtained in the territory of the Republic of Poland. The term revenue obtained in the territory of the Republic of Poland means revenue derived from a source located in Poland or revenue coming directly from Poland. The issue of the existence of a representative office, permanent establishment or a subsidiary in the territory of Poland is irrelevant to this case since, according to the regulations the decisive element was the location of the source of revenue. Russia Our Moscow Office reports on the Russian Tax Authority s recommendation affecting all Russian Tax Treaties. Background The term beneficial owner first appeared in a Russian tax treaty in 1985 and is now a standard feature of its treaties. Its impact is often highly material in any given transaction. Little has been done in terms of developing an understanding of this term for tax treaty purposes for the last eighteen years in Russian legislation, practice or tax theory. In a number of tax declarations, foreign companies had to confirm beneficial ownership of income earned in Russia, but the position of the tax authorities remained unclear. The Tax Code, which currently regulates the taxation of profits earned by foreign entities, does not mention the beneficial ownership test. However, almost all cross-border financial transactions in Russia need to consider the test (for example, on the issue of Russian eurobonds). The issues were discussed by Linkaters in the August 2001 edition of International Tax Review. Recently, the Tax Ministry issued Methodological Recommendations concerning the Taxation of profits of foreign organisations (the Recommendations ) in which, amongst other things, an attempt to clarify the beneficial ownership test was made. 8 June/July 2003

9 The definition of beneficial ownership The Recommendations set out that a foreign company has beneficial ownership of income ( has the actual rights to receive income ) when a legal basis for earning that income exists. A legal basis is defined by the Recommendations as the fact of conclusion of a contract. This view, which had in the past been used unofficially by tax officials, leads logically to the following conclusions: in any scenario when a foreign company, as the legal owner of an income, has a contract, it should be treated as the beneficial owner; and there is no actual difference between legal ownership of income and beneficial ownership in Russian tax treaties. In reality, however, the situation is rather different. The requirement to have a legal basis (i.e. a contract concluded) is merely a formality, and should be confirmed by contractual documentation. The Recommendations contain specific requirements regarding documents relating to the payment of interest and dividends. In reality, Russian officials will often rely on the approach of the OECD Commentaries to the Model Convention to the beneficial ownership test and deny the beneficial rights of nominees or agents. When the test applies In the past, officials have asked to confirm beneficial ownership with regard to all types of income, whatever a tax treaty says. The Recommendations say that the test should be applied according to a particular tax treaty, meaning that it applies to particular treaty articles (normally Dividend, Interest and Royalties). On current tax treaty refund declarations, however, the recipient of income has to confirm its beneficial ownership rights in respect of any income. Legal Status of the Recommendations The Recommendations are not binding on foreign companies and are actually intended for the tax authorities. This does not mean that in every case the officials will follow the Recommendations, and some may still take a different, more aggressive approach. Conclusion The Recommendations do not actually shed much light on understanding the tax treaty beneficial ownership test in Russia and create uncertainty for both foreign companies and Russian tax agencies. Each case should be considered in light of its particular facts, but this is unlikely to be the end of the story for foreign companies. International Tax News. 9

10 Spain Our Madrid office reports on new anti avoidance provisions. Conflict in the application of tax law The Spanish Government has submitted to the Parliament a proposal for a new General Tax Law (the "new LGT") which contains a number of new provisions on general tax rules. Among them, the new LGT provides a new anti-avoidance provision referred to as "conflict in the application of tax law" which will substitute the current "abuse of tax law" concept. Under the new LGT, a conflict in the application of tax law exists (i) if a taxpayer avoids the taxable event totally or partially or (ii) if a taxpayer reduces his/her tax liability, by means of transactions which comply with the following requirements: They are clearly artificial or inappropriate for the achievement of the result obtained. They do not have any legal or economic effects other than obtaining a tax saving and the tax saving is different from the tax position of the usual or appropriate method of doing the transaction. Procedure A conflict in the application of tax law must be declared by the Spanish Tax Authorities by means of a special administrative proceeding initiated by tax inspectors in the course of a tax audit of the taxpayer and conducted by a new consultive commission (the "Commission"). If the Commission support the position maintained by the tax inspectors, the tax may be assessed by (i) the application of the avoided tax rule corresponding to usual or proper transactions or (ii) eliminating the tax advantages obtained through the transactions carried out by taxpayers. In both cases, the tax assessment will include interest on overdue tax, but the application of tax fines is expressly excluded. Implications The new rule is a completely new measure which has the purpose of challenging tax-driven artificial structures. However, the terms under which it applies are extremely vague and imprecise and we anticipate it could lead to uncertainties in its application. Finally, it should be noted that the new provision is part of the new LGT currently being discussed in Spanish Parliament and, consequently, it may suffer changes before being finally approved. 10 June/July 2003

11 Sweden Our Swedish office reports on The Swedish CFC situation rules Sweden s law Council, a Committee of three judges from the Supreme Courts, has commented on a Government draft Bill on Controlled Foreign Companies. The Council believes that it is unclear whether the proposed Swedish CFC rules are compatible with EU law. UK Recent developments from our London Office. Loss Relief Group Litigation A Group Litigation Order was made in the England and Wales High Court on 23 May The litigation concerns claims which seek to challenge the UK group relief provisions and to assert that these provisions were or are in breach in the EC Treaty and/or the non-discrimination article on various Double Taxation Conventions. The Group Litigation Order follows the referral of the Marks & Spencer case to the European Court of Justice. Tax and the City of London In the July/August 2003 edition of International Tax Review Guy Brannan, the Head of Linklaters Worldwide Tax Practice comments on the changing international tax scene, with reference to the affect on the City of London. The article considers the recent CSFI/Study, Sizing Up the City, the tax avoidance debate and possible government reactions to developing EU tax case law. Please click here to view a copy of the article. Finance Act 2003 The Finance Act 2003 received Royal Assent on 10 July The Act contains new measures for the taxation of UK branches. The UK rules are now based on the definition of permanent establishment in the OECD Model Tax Treaty. Thin capitalisation rules are applied to branches and the measures contain rules on capital attribution. The Finance Act also includes a new transfer tax regime for Real Estate, Stamp Duty Land Tax, which is due to come into force on 1 December International Tax News. 11

12 Deutsche Morgan Grenfell plc v CIR and HM Attorney General In March 2001 the ECJ held that the UK group income rules were contrary to EU law (Hoechst). UK subsidiaries of EU parents should have been able to pay dividends without accounting for Advance Corporation Tax (ACT). The Deutsche Morgan Grenfell case has clarified the position on the limitation period for companies seeking to claim back wrongly paid ACT. The High Court held that the six year limitation period commences from the date of the ECJ judgment in Hoechst. This is particularly favorable judgment for taxpayers and can now make claims for wrongly paid ACT as far back as 1973, when the tax was introduced. The UK tax authorities are appealing the decision. US Our New York office report on a new Act which includes reductions in the tax rates on capital gains and dividends On May 28, President Bush signed the Jobs and Growth Tax Relief Reconciliation Act of 2003 (the "Act") into law. The Act accelerates previously scheduled rate reductions and reduces the tax rate on capital gains from 20 to 15 per cent. The Act also includes certain "qualified dividends" in the definition of capital gains. Thus, dividends from US corporations and certain "qualified foreign corporations" will qualify for the reduced rate applicable to capital gains. The attached note explains in more detail the changes brought about by the Act: EU A round up of developments from the Commission and the European Court of Justice. EU Savings Directive and Interest and Royalties Directive The EU Savings Directive was adopted on 3 June and is due to come into force on 1 January 2005, although this is conditional on negotiations with certain non-eu countries (including Switzerland) and relevant dependent and associated territories). Linkaters have prepared a Memorandum which summarises the key features of the Directive and comments on the implementation of the Directive in the UK. 12 June/July 2003

13 The Savings Directive was adopted as part of the tax package which also adopted the EU Code of Conduct and the Interest and Royalties Directive. The Interest and Royalties Directive will eliminate withholding taxes on payments of interest and royalties made between associated companies in difference Member States and will come info force on 1 January 2004 Negotiation of Tax Treaties It is understood that the Commission is considering the possibility of negotiating tax treaties for the Member States. This follows the Open Skies case in which the Commission won the right to negotiate landing rights with the US on behalf of Member States. In 2004, the Commission is expected to issue a communication on bilateral tax treaties and their interaction with the EC Treaty. Questions have been raised regarding the zero withholding tax in the US/UK Tax Treaty and whether this is contrary to the EC Treaty since other Member States do not benefit from this favourable rate. Any developments on this topic will be covered in International Tax News. VAT: Public Consultation on place of taxation of the supply of services European Commission Press Release 12 th June 2003 The European Commission has launched an open consultation for views on how the EU's Value Added Tax (VAT) rules concerning the place of taxation of the supply of services should be improved. The consultation is based on a paper prepared by the Commission's Taxation and Customs Directorate- General. The paper considers the idea of shifting taxation from the place where the supplier is established or has a fixed place of business to the place where the customer is located, when the customer is a trader. The Commission believes that the rule of taxation in the place where the supplier is located worked adequately when the VAT system was first introduced but, with increasing supplies of services across borders, this rule can now lead to administrative complexities, distortions of competition and double or non-taxation of international supplies of services. The Commission intends to launch a proposal in this field in autumn this year, taking into account the opinions expressed by stakeholders during the present public consultation. More information, including the consultation document, is available on the Europa website at: Investment Funds Discrimination: Germany and Austria The European Commission has decided to send official requests to Germany and Austria to put an end to discriminatory tax treatment of foreign International Tax News. 13

14 investment funds that makes it more difficult for foreign funds to market their services in these two countries. The Commission considers that certain tax provisions in the two countries violate EC Treaty rules on free movement of services and capital (Articles 49 and 56). The Commission has also decided to send a formal request for information to France concerning tax allowances that are available on income from shares issued in France but not elsewhere. This request takes the form of a letter of formal notice, the first stage of infringement procedures under Article 226 of the EC Treaty. Pensions taxation Infringement Procedures: Denmark, UK and Ireland The European Commission has decided to refer Denmark to the Court of Justice because pension contributions paid to non-danish funds are not tax deductible while contributions paid to domestic funds are. The Commission considers that Danish legislation in this respect is contrary to the principles of freedom to provide services (Article 49 of the EC Treaty) and the free movement of workers and capital (Articles 39 and 56 of the EC Treaty). Denmark has not amended its legislation despite a formal request from the Commission to do so in February The Commission has also expressed its serious concerns as to the compatibility with EU law of the tax legislation of the United Kingdom and Ireland regarding pension contributions. It has therefore decided to issue formal requests to the UK and Ireland for information concerning their legislation and practice. These requests take the form of so-called 'letters of formal notice', the first stage of formal infringement procedures under Article 226 of the EC Treaty. They will have two months to reply. Consultations The EU Commission s Taxation and Customs Union Directorate-General has just published two summary reports on the results of the following consultations. Click on the below links to view the reports. The application of IAS in 2005 and the implications for the introduction of a consolidated tax base for companies EU-wide activities; and The experimental application of Home State Taxation to Small and Medium Sized Enterprises in the EU. C-422/01 Försäkringsaktiebolaget Skandia (publ), Ola Ramstedt v Riksskatteverket European Court of Justice Judgment 26 th June 2003 The European Court of Justice has held that the Swedish tax rules favouring pensions taken out with Swedish insurers over those from another member state are incompatible with EU law (Article 49). 14 June/July 2003

15 The Court held that Article 49 EC precludes an insurance policy issued by an insurance company established in another Member State which meets the conditions laid down in national law for occupational pension insurance, apart from the condition that the policy must be issued by an insurance company operating in the national territory, from being treated differently in terms of taxation, with income tax effects which, depending on the circumstances in the individual case, may be less favourable. The justifications of (1) fiscal cohesion and (2) effectiveness of fiscal controls and (3) preservation of the tax base were all rejected. C-305/01, Finanzamt Groß-Gerau v MKG-Kraftfahrzeuge-Factory GmbH European Court of Justice Judgment 26 th June 2003 The European Court of Justice has held that a person who assumes risk in buying debts and invoices customers for commission is taxable for VAT purposes. The Court ruled that: A business which purchases debts, assuming the risk of the debtors' default, and which, in return, invoices its clients in respect of commission pursues an economic activity for the purposes of Articles 2 and 4 of the Sixth Directive, so that it has the status of taxable person and thus enjoys the right to deduct tax under Article 17 thereof. An economic activity by which a business purchases debts, assuming the risk of the debtors' default, and, in return, invoices its clients in respect of commission, constitutes debt collection and factoring within the meaning of the final clause of Article 13B(d)(3) of the Sixth Directive (77/388) and is therefore excluded from the exemption laid down by that provision. The judgment does not deal with the situation where the factor purchases receivables at a discount and does not charge a commission. In this situation, it is unlikely that the factor be treated a making a taxable supply. C-442/01, KapHag Renditefonds 35 Spreecenter Berlin-Hellersdorf 3. Tranche GbR v Finanzamt Charlottenburg European Court of Justice Judgment 26 th June 2003 The European Court of Justice has ruled that a partnership which admits a partner in consideration of payment of a contribution in cash does not effect towards that person a supply of services for consideration within the meaning of Article 2(1) of Sixth Council Directive. International Tax News. 15

16 Bangkok 20th Floor Capital Tower All Seasons Place 87/1 Wireless Road Bangkok Tel: (66) Fax: (66) Bratislava Hlavné námestie 5, 1st Floor Bratislava, Slovak Republic Tel: (421-2) Fax: (421-2) Brussels Rue Brederode 13 B Brussels Tel: (32-2) Fax: (32-2) Frankfurt am Main Mainzer Landstraße Frankfurt am Main Tel: (49-69) Fax: (49-69) London One Silk Street London EC2Y 8HQ Tel: (44-20) Fax: (44-20) Munich Prinzregentenplatz München Tel: (49-89) Fax: (49-89) New York 1345 Avenue of the Americas 19th Floor New York, NY Tel: (1) Fax: (1) Paris 25 rue de Marignan Paris Tel: (33) Fax: (33) Prague Palác Myslbek Na Příkopě Prague 1 Tel: (420) Fax: (420) Rome Via delle Quattro Fontane, 20 I Rome Tel: (39-06) Fax: (39-06) São Paulo Rua General Furtado do Nascimento, São Paulo - SP Tel: (55-11) Fax: (55-11) Warsaw Warsaw Towers ul. Sienna 39 7th floor PL Warsaw Tel: (48-22) Fax: (48-22) Editors: Neal Todd Vincent Maguire This publication is intended merely to highlight issues and not to be comprehensive, nor to provide legal advice. Should you have any questions on issues reported here or on other areas of law, please contact one of your regular contacts at Linklaters, or contact the editors. Linklaters. All Rights reserved neal.todd@linklaters.com vincent.maguire@linklaters.com Please refer to for important information on the regulatory position of the firm. We currently hold your contact details, which we use to send you newsletters such as this and for other marketing and business communications. We use your contact details for our own internal purposes only. This information is available to our offices worldwide and to those of our associated firms. If any of your details are incorrect or have recently changed, or if you no longer wish to receive this newsletter or other marketing communications, please let us know by ing us at marketing.database@linklaters.com 16 A /0.4/25 Jul 2003