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NON-RESIDENT WITHHOLDING

In August of this year, the Canadian revenue authorities issued a discussion paper on the subject of waivers from the withholding requirement for payments to non residents. The administrative positions set out are onerous. The government expects to finalize and implement the changes to its waiver procedures with effect from January 1 1999. Some moderation in these rules would be welcomed.

October 01 1998

CVC and Cinven look to Ernst & Young

Dutch packaging and distribution group KNP BT, has agreed to sell its packaging division to UK venture capital groups CVC and Cinven. The deal is worth Fls 3.4 billion ($ 1.7 billion).

September 30 1998

Freshfields advises Marsh & McLennan

US insurance broker Marsh & McLennan is to buy UK insurance broker Sedgwick for $1.25 billion. Marsh & McLennan was known to be looking at the UK insurance sector, and was interested in Willis Koroon until it was bought by Kohlberg Kravis Roberts last month. The acquisition will create the world's largest insurance broker.

September 30 1998

Ranstad Holding recruits Davis Polk & Wardwell

Florida-based AccuStaff Incorporated has agreed to sell its Strategix business to Dutch business services company Ranstad Holding. Strategix provides staffing and outsourcing services, principally in the US. The transaction is valued at $850 million.

September 30 1998

OECD report highlights hidden taxation

A report by the OECD has found that the tax burden in its member states is continuing to rise. The report notes an increase in the average tax burden to 37.7% of gross domestic product in 1996, compared with an average of 33% in 1980. The annual report, entitled Revenue Statistics in OECD Member Countries, details the level and structure of the tax burden in the OECD's 29 member countries. It is designed to be an aid to governments and companies in policy formation.

September 30 1998

GAAR: empty threat or deal stopper?

General anti-avoidance rules fill tax advisers the world over with trepidation. With good reason? Oliver Ralph compares practices and precedents across international jurisdictions, to discover the substance behind the rules

September 30 1998

TREATY WITHHOLDING RATES FOR TECHNICAL SERVICES

India's rate of taxation of royalties and fees for technical services varies between 10% and 20%. An interesting position has emerged after the German treaty was entered into on November 29 1996. This treaty provides for a withholding rate of 10% on royalties and fees for technical services.

September 30 1998

TRANSFER PRICING: GERMAN POSITIONS SHIFTING ON PROFIT SPLIT AND COMPARABLE PROFIT METHODS

Senior German tax officials responsible for Germany's international tax policies have consistently stated in public that comparable profit methods and transactional net margin methods will not be accepted by the German tax authorities, and that profit splits are only acceptable in rare instances as a method of last resort. They have also frequently expressed their opposition to US-style economic analysis and voiced serious reservations concerning Advance Pricing Agreements (APAs).

September 30 1998

TAXATION FOR ACQUISITION OF COMPANIES' OWN SHARES; PARTIAL ABOLITION OF STAMP DUTY IN FINLAND

Finland's amended Companies Act entered into force on September 1 1997.

September 30 1998

THE IMPORTANCE OF TAX-RELATED CLAUSES IN CONTRACTS BETWEEN SPANISH RESIDENTS AND NON RESIDENTS

Spanish tax legislation has been always sensitive to the potential risk that non-resident (non-established) taxpayers deriving income from Spanish sources do not comply voluntarily with their tax obligations.

September 30 1998

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