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Directive 69/335/EEC — Indirect taxes on the raising of capital — Tax on transfer of shares not listed on a stock exchange.

The February 1998 federal budget contained several international tax measures which have now been released as draft legislation. There are a few surprises.

Switzerland has concluded tax treaties with well over 40 countries. The majority of the treaties do not contain specific treaty abuse provisions, a fact which has long been put down to the unilateral treaty abuse decree, passed by the Swiss government in 1962.

To revitalize the long-stagnating Japanese economy, reform of the corporate tax system is planned. At the time of writing, the full details of the tax reform have not been finalized. However, an outline of the key aspects is provided. The following highlights the major proposed changes.

Tax losses are normally carried forward on the profits of the following five years (except for losses derived from the depreciation of fixed assets), unless the tax paying entity elects to carry-back its tax losses on its profits made during the preceding three years.

Indian tax professionals have long debated whether the minimum alternative tax applies to foreign companies doing business in India through permanent establishments.

A company is resident in Ireland for tax purposes if it is managed and controlled there. The fact that a company is incorporated in Ireland does not, of itself, impact on the tax status of the company in Ireland. The number of Irish incorporated, non-Irish resident companies has grown significantly in recent years, and they are now used extensively by non-Irish residents in the management of their affairs.

National elections held in September 1998 brought to office a new coalition government of Social Democrats and Greens under Chancellor Gerhard Schröder. In early November, the new government published a major tax reform bill in draft form. In addition to their majority in the federal parliament, the parties composing the new government also control the federal council, which is accordingly expected to ratify the bill in its final form. It was inability to secure the consent of the federal council which doomed the 1997 tax reform efforts of the prior government.

The Finnish parliament will decide on the amendment of the Act on Taxation of Foreign Intermediate Companies later this year following the government bill (149/1998) presented to the parliament in October 1998. The government bill contains amendments to Article 2 of the Act regulating the scope of application of the Act.

The temporary importation of goods into the Russian Federation has become an increasingly problematic area for accredited representative offices of foreign entities. Many representative offices have goods which were imported on a temporary basis and are now reaching the end of their useful life. This raises the question of what should be done with these imported goods – and how much will it cost?