Financial Instruments Tax and Accounting Review

In the last two issues FITAR has delved into the vexed issue of fair value accounting for credit derivatives. Their tax treatment is similarly opaque.

Vincent Keaveny of the International Securities Group at Norton Rose says that the introduction of a new legal framework for securitisations, Deutsche Bank’s recent innovative transactions, the advent of the euro and greater international investor understanding of domestic financial institutions could herald a new era in securitisation activity in Portugal.

The three-year deadlock over proposals for an EU-wide withholding tax on savings by non-residents, was finally broken at the ministerial summit in Portugal last month. The Germans, especially, had sought to impose the tax as a means to prevent tax..

Over the years the Inland Revenue has assembled a powerful toolkit of anti-avoidance provisions aimed at counteracting what it perceives as tax avoidance in financing transactions. In the second part of their article, Stephen Weston and Darren Docker of Arthur Andersen continue their guide to the different means of attack available to the Revenue.

One of the most complicated pieces of legislation introduced by the present Government, the Financial Services and Markets Act 2000, finally became law on 14 June 2000. More than three years have passed since the reforms to the UK financial services regulatory regime were first announced and the Act, the culmination of those reforms, ended up being the most amended piece of legislation in history as it passed through Parliament. The Act will probably not be brought into force until Spring/Summer 2001. Given that it has more than 430 sections and some 22 schedules, and still needs over 50 pieces of secondary legislation before it can be put into effect, the aim of this article by Stephen Fletcher of Linklaters & Alliance is to provide brief introduction to what the new Act was designed to achieve and the main areas that it covers.

At the time that this issue went to press, the Finance Bill was about to start its Report Stage. In this article John Lindsay considers developments during the Committee Stage. As readers will be aware, the Finance Bill introduced changes to group relief, capital gains groups, double tax relief, controlled foreign companies, the foreign exchange local currency provisions and stamp duty.

The race is on to create the first truly global equity market which can trade continuously. Ten national stock exchanges recently entered into discussions to create links and establish common trading rules and a central counterparty. They are the..