Number 4 - 2007 contains the following:
 

The author considers the most important changes to the Netherlands Corporate Income Tax Act that have been introduced by the Act "Working on Profit", including the reduction in the corporate income tax rate to primarily 25.5%, the introduction of "royalty" and "interest" boxes, and the amendments to the participation exemption regime. In conclusion, the changes to the Netherlands dividend withholding tax regime are outlined.

This article first considers the implications of the recent Philip Morris case and undertakes an in-depth investigation of the legal structure and operations of private equity funds in Italy. In relation to this, the author then analyses the circumstances under which, according to Italian and international tax rules, a non-resident person may be deemed to have a permanent establishment (PE) in Italy. Finally, the implications of the allocation of profits to a PE are considered.

In Part 2 of this article, the author concludes his discussion on the scope of the participation exemption regimes in the Nordic countries started in Part 1. A detailed consideration of the relevant anti-avoidance rules forms the subject matter of the remainder of Part 2.

This article analyses the development of the doctrine of substance over form with regard to tax reform in Lithuania. Lithuanian court jurisprudence in relation to this issue is then examined. The article concludes with a consideration of the EC law implications of Lithuania's accession to the European Union for this topic.

On 1 January 2007, Bulgaria and Romania acceded to the European Union. This article examines the tax system of Bulgaria in relation to the acquis communautaire. A subsequent article will consider Romania in this respect.
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Central/Eastern Europe - Taxation & Investment

A new system of dividend taxation in Poland has been introduced by way of amendments to the Corporate Income Tax Act. The new provisions entered into force on 1 January 2007 and substantially amend the tax environment for direct investment in Poland. It should be noted that the provisions may give rise to problems with EC law in respect of some of Poland's treaty partners.

Slovenia implemented a new tax reform in 2006. In this note, the author considers some of the major changes of the reform that primarily reflect the implications of tax competition and economic growth, and the requirements of EC law.