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On March 11 1999 the Supreme Court allowed a double deduction of expenses, once for Japanese and once for Dutch corporate income tax purposes. However, to put the case in context, it is first necessary to provide some background information on transfer pricing and explain the concept of an informal capital contribution in the Netherlands. Dutch tax law does not contain specific provisions regarding transfer pricing. Taxable profits are determined by applying the general rules detailed in Articles 7 and 9 of the Dutch Income Tax Act, and there is a wealth of case law in this respect.

As discussed in the previous update, the Australian government has set up a committee to report on the reform of Australia's business tax system. The reforms considered in relation to interest deductibility from an international perspective are summarized below.

The convention on the elimination of double taxation in connection with the adjustment of profits of associated enterprises (the Arbitration Convention) comes into force in Finland on May 1 1999. This relates to Denmark, Italy, Luxembourg, the Netherlands, Portugal and the UK.

The European Court of Justice’s decision in ICI v Colmer has forced the UK Inland Revenue to alter the rules governing group relief. Yash Rupal and Neal Todd of Linklaters & Alliance explore the new opportunities available throughout the EU

Director of Tax and Corporate Strategy UK

Watkins leaves tax boutique behind Canadian tax lawyer Donald Watkins has joined Osler Hoskin & Harcourt in Calgary as a senior partner.

From April 1 1999 foreign banks and securities dealers with no presence in Switzerland will be able to trade on the Swiss stock exchange. This change has triggered amendments to Swiss stamp tax legislation. Charles Hermann of KPMG, Banking Tax Group, Zurich reports

As stock option plans become an increasingly popular means of remuneration, tax authorities have responded by lightening the rules that govern them. Sven Tischendorf and a team from the Conference of European Lawyers discuss the opportunities available

The days when the Netherlands was the location of choice for all foreign holding companies are over. As EU tax rates converge and the parent-subsidiary directive takes effect, competition for business is hotting up. Allan Cinnamon of BDO Stoy Hayward, London reports

Freedom of establishment — Tax legislation — Tax on company profits.