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Transfer pricing. New rules permit tax free repatriation of cash after a Section 482 adjustment.

The IRS released Rev. Proc. 99-32, the long-awaited revision of the revenue procedure authorizing the tax-free repatriation of cash following a §482 adjustment, on August 2 1999. Revenue Procedure 99-32 finalizes earlier proposals to update the previous rules that were first issued in Rev. Proc. 65-17.

September 30 1999

Carrefour and Promodes in friendly merger

Carrefour and Promodes have merged to form Europe's largest retailer. The Ffr111 billion ($17.7 billion) deal will produce a combined chain of 9000 stores, and anticipated net sales of Ffr355 billion ($56.5 billion) this year.

September 30 1999

Stock options – new developments

The tax treatment applicable to stock option schemes has recently undergone some changes.

September 30 1999

Major revision of the Dutch tax system for the 21st century

On September 14 1999, the Dutch cabinet submitted to parliament a proposal for a new personal income tax that is proposed to come into force on January 1 2001. The proposed legislation is the core of a major revision of the Dutch taxation system, which will also involve amendments to existing laws.

September 30 1999

Government bills for taxation in 2000

The Finnish government has introduced Bills to amend the Income Tax Act for the tax year 2000. The government has introduced the following amendments.

September 30 1999

Indian rulings spark treaty uncertainty

A number of recent rulings in India have denied treaty relief to residents of low-tax jurisdictions. Frank D’Souza, Keyur Shah and Jatin Goradia of Arthur Andersen in Mumbai examine the consequences for other double tax agreements signed by India

September 30 1999

New guidelines for taxation of non-resident artists and sportsmen

Under Austrian national law, payments made to non-resident artists and sportsmen for their cultural or sporting activities in Austria are subject to a 20% withholding tax. Recently, the Austrian Ministry of Fiscal Affairs issued new guidelines for the income taxation of non-resident artists and sportsmen. The cornerstones of these new guidelines are the following:

September 30 1999

New Zealand irons out tax

The New Zealand government has ironed out a number of kinks in the tax system. Changes have been made to the conduit tax rules and joint bank accounts, among other areas. Craig Elliffe and Nathan Banks of KPMG in Auckland look at the consequences for multinationals

September 30 1999

Turkish emergency taxes face tough passage

The Turkish government's emergency tax initiative is facing a difficult passage through parliament.

September 30 1999

French government agrees to APAs

The French administration recently finalized guidelines concerning the possibility of negotiating an Advance Pricing Arrangement (APA) in France.

September 30 1999

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