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  • The Notice on the Taxation of Commodity Futures Transactions [Goushuifa (1997) Number 158], published by the State Tax Bureau on October 9 1997, clarifies the deductibility of fees payable by futures brokers.
  • The Australian Taxation Office (ATO) has recently released a taxation ruling (TR97/20) which explains the acceptable arm's-length methodologies that Australian taxpayers must use for their international dealings.
  • A Netherlands individual moved from the Netherlands to the UK in April 1984. In the UK he had the status of a non-domiciled resident. He had a so-called substantial interest in a BV resident in the Netherlands. Under Netherlands domestic law, a capital gain on the sale of substantial interest is subject to individual income tax. As of January 1 1997 the substantial interest tax amounts to 25%. Prior to that date, the tax rate was 20%. It is to be expected that as of January 1 2001, the rate will be increased to 30%.
  • 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.
  • Supreme Court overrules legality of certain tax resolutions passed by the Kirienko government
  • Collective investment funds or mutual funds have been around for a long time. They offer the opportunity to investors, large and small, who may or may not be acquainted with investment techniques, to pool their funds with the primary aim of spreading their investment risk and obtaining stronger purchasing power. A collective investment fund can either be a close-ended or open-ended fund.
  • General Electric and Lockheed Martin have agreed to a tax-free exchange. General Electric will exchange its holding of Lockheed Martin preferred stock, and some non-core businesses, in return for a wholly-owned subsidiary of Lockheed Martin. The subsidiary owns Access Graphics, LM Aerostructures, and an equity stake in telecommunications service provider, Globalstar.
  • 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.