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Ministero delle Finanze and Spac SpA

Recovery of sums paid but not due — Procedural time-limits under national law.

September 14 1998

SWITZERLAND-FRANCE TAX TREATY

France and Switzerland have signed a new protocol to the existing income tax treaty of 1966/1969, which entered into force on August 1 1998. The major changes are outlined below. Nevertheless there is still uncertainty as to whether the protocol will have an impact on the Swiss branches of French companies in regard to the French anti-abuse legislation. This point is still being discussed.

August 31 1998

CFCS: CHANGES TO THE EXCLUDED COUNTRIES LIST; REVIEW OF DOUBLE TAXATION RELIEF FOR COMPANIES; ABOLITION OF ADVANCE CORPORATION TAX

As part of the move to bring the controlled foreign corporation (CFC) legislation within corporation tax self- assessment, the UK Inland Revenue has announced that the excluded countries list exemption is to be brought within regulations so that in future UK companies will have a legal basis for relying on it.

August 31 1998

VAT TREATMENT OF

A ruling of the Brandenburg tax court raises interesting issues concerning the value-added tax (VAT) treatment of companies which have little substance and engage in no meaningful economic activity.

August 31 1998

KIWI LOANS – AGAIN

In the July/August issue of International Tax Review, we commented on the Federal Court of Appeal decision in Shell Canada Limited, which disallowed certain interest deductions relating to weak currency financing transactions. While it is still not clear whether an appeal of that decision will be heard by the Supreme Court of Canada, the plot has thickened slightly with the release of a second case, Canadian Pacific Limited.

August 31 1998

Coca-Cola Beverages looks to Linklaters

Coca-Cola Beverages, one of the largest bottlers of soft drinks in Central and Eastern Europe, has floated on the London Stock exchange. The flotation valued the company at over £1.7billion ($2.72billion). The Coca-Cola Company expects to hold 50.5% of Coca-Cola Beverage's shares. The London listing is to be followed by a listing in Sydney. Coca-Cola Beverages was formed by Australian company Coca-Cola Amatil and then demerged in order to be listed.

August 31 1998

UK corporate tax: the dawn of a new era

The future is a different country for international corporate tax planners; they do things differently there. Or at least it will be for those used to dealing with the UK’s present corporation tax system.By Susan Symons, PricewaterhouseCoopers, London

August 31 1998

Taxfax

Collection techniques: Ukraine goes for tax hostages...

August 31 1998

Saks looks to Skadden Arps

Saks Holdings, the company which owns the famous Saks 5th Avenue store in New York is to merge with Proffitts, an acquisitive retail group based in Birmingham, Alabama. The new company will operate 330 stores across the US. The deal is worth $2.1 billion.

August 31 1998

GTE calls on O’Melveny & Myers

US telecoms companies GTE and Bell Atlantic are to merge. The deal will create a company worth approximately $121 billion.

August 31 1998

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