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  • The economic stability experienced during the last few years, together with greater interest on the part of individuals in this type of insurance, has accelerated the development of life insurance and related products, in Argentina. International corporations, aware of this development, have started to set up and compete in this new market.
  • New government measures have just been announced in Brazil, as a result of the turmoil which engulfed the Brazilian economy last month.
  • To increase the attraction of Switzerland as a holding location and a business headquarters site, various favourable tax reform measures were adopted by the Swiss parliament in October 1997. Except in the unlikely case of a referendum, the reform will probably enter into force as of January 1 1998. The most significant measures are discussed below.
  • Under the 1997 Mexican income tax reforms, all Mexican companies with international related-party transactions are obliged to document that their transfer prices were determined in accordance with the arm's-length standard. In particular, they must document that one of the transfer pricing methods specified by law has been employed.
  • 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.