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  • Recovery of sums paid but not due — Procedural time-limits under national law.
  • Recovery of sums paid but not due — Procedural time-limits under national law.
  • 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.
  • 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.
  • Capital gains on the repayment to non-residents of units in Spanish mutual funds are taxed at 35%, unless the non-resident in question is protected by a tax treaty or is an EU resident, in which case the capital gain will be tax exempt.
  • Financial authorities in Austria and Germany have continued negotiations over the new double tax treaty of May 1998. Representatives of the Austrian Ministry of Finance have already disclosed the most important changes to the existing double tax treaty that the authorities were able to agree on. Although the negotiations have not yet been finalized in all aspects, it is likely that the following changes will be effective from the tax year 2000.
  • New Administrative Principles on transfer pricing documentation will mean substantial exposure for taxpayers lacking an appropriate defence strategy. Gianmarco Monsellato of Deloitte & Touche, Paris advises taxpayers on how to survive in a harsh climate
  • US-based multinationals represent the largest proportion of companies investing in the UK. How will substantial changes to the UK advance corporation tax system affect these companies? By Lawrence Pollack, David Porter, and Frances Corrie, KPMG New York and London
  • UK firm British Petroleum is to merge with US oil company Amoco in the world's largest industrial merger. The new company will be known as BP Amoco and will be worth around $110 billion. The equity split will be 60% to BP shareholders and 40% to Amoco shareholders.
  • Inco of Canada, the world's largest nickel producer, has agreed to sell its alloys operation to Special Metals of the US for around $408 million. The deal is part of Inco's sale of non-core assets to pay debts.