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  • Germany
    A recent tax court decision raises the possibility that an important new exception may be emerging in the complex statutory thin-capitalization rules which have been in force in Germany since 1994.
    March 01 1998
  • Norway
    In the May 1997 edition of International Tax Review we briefly commented on proposed changes to regulations regarding a Norwegian parent company's right to credit for underlying foreign corporate taxes relating to dividends received from foreign subsidiaries. The bill passed parliament and is effective for dividends received from the fiscal year 1997.
    March 01 1998
  • Finland
    Under Finland's legislation on the Taxation of Shareholders of Foreign Intermediate Companies (the Act), resident taxpayers in Finland must notify the Finnish tax authorities of their holdings in foreign companies. The resident taxpayers are liable to pay tax on their share of the profits of such companies in accordance with certain conditions.
    March 01 1998
  • France
    By virtue of article 115 quinquies of the French tax code, after-tax profits realized by foreign companies in France (especially through a French branch) are deemed to be distributed to non-French tax resident partners, and are subject to a 25% branch tax (with possible limitation or exemption, depending on the applicable tax treaty).
    March 01 1998
  • The Taxation of Intangibles (Special supplement): United States
    A special report prepared by Michael Knee, Washington and Robert Misey, Nashville Deloitte & Touche LLP
    March 01 1998
  • Illustration
    The Taxation of Intangibles (Special supplement): United Kingdom
    A special report prepared by Christopher Fitzgibbon of Deloitte & Touche, London
    March 01 1998
  • Canada
    As part of its April 26 1995 technical bill of proposed amendments to the Canadian Federal Income Tax Act, Canada's Department of Finance released sweeping changes to the definition of, and rules relating to, the concept of taxable Canadian property (TCP).
    March 01 1998
  • Expatriate taxation in Europe Survey Part three: The discreet charms of expat tax
    Italy, Spain, Sweden and Switzerland are not celebrated expatriate tax locations, but as the third and final part of this survey shows, they offer some hidden attractions, some planning opportunities, and present some pitfalls to watch out for
    March 01 1998
  • US position raises new questions
    A new provision and temporary regulations should simplify the complex issues relating to passive foreign investment companies. Unfortunately, the rules inadequately address key issues. By Dale Collinson and Patrick Carmody of Willkie, Farr & Gallagher in New York
    March 01 1998
  • The Taxation of Intangibles (Special supplement): Japan
    A special report prepared by Jonathan Stuart-Smith and Tomohiko Kaneko of Deloitte Touche Tohmatsu, Tokyo
    March 01 1998
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