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Pursuant to Taiwan tax laws and regulations, dividends received by international investors are subject to a 20% withholding tax at the time of remittance by Taiwanese investee/issuing companies. The said withholding tax rate on dividends may be reduced (for example from 20% to 10%) if the beneficial owners of the dividend income are from countries that have executed DTAs with Taiwan.

Mikhail Filinov Marina Malakha In the November 2006 issue of International Tax Review we wrote about the draft law on the proposed Russian holding company regime. Recently the law passed the two remaining readings with the lower chamber of parliament and was approved by the upper chamber of parliament. After presidential approval and official publication the law shall become effective January 1 2008.

Paul Chambers Samantha Nonnenkamp Following the repeal of the 1929 Holding Company legislation, the government has introduced a new investment vehicle for private wealth investment. The law introducing the "Société de Gestion de Patrimoine Familial" (or SPF) was passed by the parliament on April 26 2007 and published in the Luxembourg official gazette on May 14 2007.

Stephen Nelson The new PRC enterprise income tax law provides that venture capital enterprises established in China are eligible for tax incentives in the form of taxable income deductions calculated by reference to their investment amounts. However, the law does not provide details on how and when the deduction can be made. Nevertheless, it is generally believed that this provision of the law is designed to allow for the continued availability of existing incentives for venture capital enterprises set forth in a State Administration of Taxation notice (Caishui (2007) 31), issued on February 7 2007.

Sweden is an interesting alternative to the more traditional holding company locations, says Carl Pihlgren of Ernst & Young

Welcome to the special feature on holding companies in the June issue of International Tax Review.

Nélio B. Weiss Philippe Jeffrey On March 1 2007 the Brazilian tax authorities issued the Interpretation Declaratory Act number 1 (ADI 1) (which is an official interpretation from the Brazilian tax authorities), setting forth their understanding in connection with payments of royalties and technical service fees made under the Brazil-Mexico Convention for the Avoidance of Double Taxation.

Pepper Hamilton in New York has announced that Steven Bortnick, a lawyer concentrating on domestic and international tax and private equity matters, has joined the firm as a partner. He will divide his time between the firm's New York and Princeton offices.

Antonio Ruiz Costa Rica Opening of new free trade zone parks

Chris Van Loan In an announcement on May 14 2007, the Minister of Finance stepped back significantly from a controversial proposal in the March 19 2007 federal budget to restrict the deductibility of interest and other borrowing costs of money used to acquire shares of a foreign affiliate. The original budget proposal faced a growing chorus of opposition from the business community which contended that the proposal would significantly affect the ability of domestic companies to make acquisitions outside of Canada. The May 14 2007 announcement responded to these concerns by limiting the ambit of the proposal and delaying its effective date until the beginning of 2012.