Global dispatch, October/November 2008

Danish termination of French, Spanish treaties effective 1 January 2009 -- Denmark releases rules on “un-checking” Danish company, amendments to participation exemption rules -- 2009 Irish Budget leaves 12.5% corporate tax rate intact -- Luxembourg proposes extending dividend withholding tax exemption to all treaty countries -- 2009 Norwegian Budget proposes amending participation exemption rules, emigration liquidation tax, and exit tax -- Swedish tax bill limiting interest deductions on intercompany loans presented to parliament -- PRC Circular confirms taxes / expenses not deductible in computing withholding on passive income paid to nonresidents -- Recent Indonesian tax developments -- Singapore circular clarifies APA procedures -- Singapore draft circular says arm’s length principle applies to related-party loans and services -- Taiwan clarifies tax treatment of capital gains arising from mergers -- Argentina reduces tax benefits for publicly traded financial trusts, investment funds -- US Senate approves new tax treaties with Bulgaria, Iceland, protocol to US-Canada income tax treaty; 2008 entry into force possible -- Proposed 1999 US-Italy tax treaty back on track