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Since April 1996, the French tax authorities have been able to require specific information as regards intra-group transactions, according to a strict procedure (article L13B of the French tax code for tax procedures). If the response of the enterprise is considered insufficient, there is a risk of a fine of Ffr50,000 ($8,300) for each financial year the request concerns. The tax authorities can make their own tax basis assessment from whatever information is available to them (although the procedure remains adversarial).

The 1998 Japan Tax Reform has now been passed by the Japanese parliament (see International Tax Review February 1998) and became law effective April 1 1998.

Legislation to restrict trading in franking credits has recently been introduced into parliament, restricting the use of franking credits by Australia-resident shareholders. The restrictions apply where the company is effectively wholly-owned by non-resident or tax-exempt entities.

The first 1998 taxation notice released by the Ministry of Finance and the State Administration of Taxation on February 25 1998 – The Circular on Income Tax Issues Concerning China-sourced Guarantee Fees Derived by Foreign Enterprises – dealt a severe blow to foreign bankers, who recently lobbied successfully against withholding tax on interest.

Tax treaty negotiations in Latin America are proceeding at a rapid pace. Jorge Gross and John Salerno of Price Waterhouse LLP, Miami and Boston alert readers to the changes, and to the tax planning opportunities for multinationals

Argentina's Executive has announced a comprehensive package of fiscal measures, which has been submitted to Congress for approval.

Canada’s Technical Committee on Business Taxation finds an uneven tax system at odds with development priorities and a highly taxed service sector. By Stephen R Richardson of Tory Tory DesLauriers & Binnington, Toronto

Burdens imposed on non-US financial institutions by new US withholding rules can be alleviated by a qualified intermediary agreement with the IRS. By Barbara Hanrehan and Alan Shapiro of Deloitte & Touche, LLP New York and Washington, DC

In the first of three articles on investment in Indochina, John Fisher and Tim Watson of Coopers & Lybrand, Melbourne and Ho Chi Minh City analyse Cambodia’s attractions, which include flexibility and some unique tax incentives and guarantees

Hong Kong’s 1998/1999 budget presented the Special Administrative Region with a challenge – to ballast the economy against instability, but at the same time attract investment. Sunny Choong of Price Waterhouse, Hong Kong examines the results