ITR Search | International Tax Review

Use of losses Following Purchase of a Corporate Shell

The German tax code was revised in 1990 to permit net operating losses to be carried forward indefinitely for income, corporation, and trade tax purposes. In the case of income and corporation tax, the indefinite carryforward applies to losses which cannot be carried back to either of the two years preceding the year in which they were incurred. The trade tax has no loss carryback provision.

February 01 1998

Changes to tax on passive income and individual taxation

France's finance Act for 1998, applicable to 1997 income, is characterized by the suspension of the tax reduction plan announced by the previous government (personal income tax rate maintained at the maximum of 54%), and by an increase in the taxation of passive income.

February 01 1998

Tax reform proposals

In our previous article (see International Tax Review, Dec/Jan 1998, p55), we highlighted potential tax law changes proposed by Japan's ruling Liberal Democratic Party (LDP). The LDP's tax reform proposals have now been adopted by prime minister Hashimoto's Cabinet.

February 01 1998

Victory for Foreign Banks

In June 1997, the Chinese government announced its intention to collect a withholding tax of 10% on interest derived by foreign banks on offshore inter-bank loans on-lent to their branches in China.

February 01 1998

Gibraltar bids for captive market

Captive insurance can be an efficient vehicle for protecting companies against risk. Chris Johnson of Norwich Union, Gibraltar examines the options on offer, the role of tax in reducing costs, and the appeal of Gibraltar as a domicile for the captive owner

February 01 1998

Actively seeking expatriates

Peter Vansteenkiste of Coopers & Lybrand, Antwerp and Eugene Weultjes of Coopers & Lybrand, Rotterdam assess the attractions of two traditionally expatriate-friendly regimes – Belgium and the Netherlands

February 01 1998

Dual income versus capitalization

Italy has introduced a dual income tax system, in the hope of overturning existing levels of capitalization. Paul Smith and Piergiorgio Valente of Ernst & Young, Milan, assess the benefits of the new system, and question the likelihood of a serious challenge to debt/equity policies

February 01 1998

Korea: variations on OECD theme

Korea’s International Tax Coordination Law updates the country’s transfer pricing regime, to deal with a growing volume of international transactions. Brian Park of Price Waterhouse, Seoul looks at the detailed requirements of the regime

February 01 1998

Guardian Royal Exchange buys PPP Healthcare

UK insurance group Guardian Royal Exchange has paid £435 milllion ($700 million) for PPP Healthcare, the UK's second largest private medical insurer. The acquisition gives the group a strong position in the private medical insurance and long-term care markets PPP Healthcare was advised by Linklaters in London. Tax partner Charles Hellier, and tax assistants Sarah Squires and Paul William worked on the deal.

February 01 1998

Interface buys stake in Readicut International

US carpet manufacturer Interface has bought the European carpet division of UK company Readicut International for $50.3 million. Readicut was advised by UK law firm Eversheds with tax advice from partner Richard Hutchinson in Leeds.

February 01 1998

Search results for