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The following important tax developments have taken place in India.

Dividends received by a Finnish company on direct foreign investment are generally exempt from tax. If the Finnish company has distributed the dividend received from a foreign country to its foreign owners, it may previously have been subject to a supplementary tax. As a result, income received from another country may also have been taxed at a corporate tax rate in Finland.

Further to Australia's Review of Business Taxation, a number of capital gains tax changes became law from December 10 1999. Included in the measures are scrip-for-scrip rollovers and improved incentives for venture capital investment.

Many Canadian non-residents with no permanent establishment in Canada might well anticipate that remuneration for services rendered in Canada should not be subject to withholding tax. The federal authorities do not agree and require a 15% withholding on fees, commissions or other amounts paid to a non-resident in respect of services rendered within Canada. (A further 9% Quebec withholding is required in respect of non-resident services rendered in that province.) If the non-resident is not subject to Canadian tax, they must apply for a refund by filing a Canadian tax return. If the non-resident is subject to Canadian taxation, the withheld amount can be applied to the non-resident's Canadian tax liability.

At present, in Ireland, there is a difference in the tax treatment of unit-linked investment products in the form of life assurance policies or mutual funds, dependant on whether they are available to Irish residents (Domestic Funds) or are exclusively available to non-residents (IFSC Funds). In the International Financial Services Centre (IFSC) where such products are sold exclusively to non-Irish residents, both the fund itself and the policy holders are exempt from Irish tax. In the case of such products outside the IFSC, however, Irish residents may be unitholders and the fund is subject to tax on an ongoing basis at the standard income tax rate of 24% (22% from April 6 2000).

Corporate tax

The UK Inland Revenue issued a press release on January 14 announcing that legislation would be introduced in the next Finance Bill to widen the circumstances in which companies can calculate their taxable profits in a currency other than sterling. The new rules will apply to accounting periods beginning on or after January 1 2000.

Bruno Gouthiere, of Bureau Francis Lefebvre, Paris analyzes the reasons for repatriating a Luxembourg captive reinsurance business back to France

Australia’s thin capitalization rules are covered in the wholesale tax reforms put forward in the Ralph Report. Peter van den Broek of Clayton Utz, Melbourne outlines the likely changes and their impact for international operations

The Dutch Supreme Court has ruled that a German engineering company had a permanent establishment in the Netherlands, and therefore the Netherlands was entitled to levy wages tax on the wages of German employees who worked occasionally in the Netherlands.