Table of Laws Cited

Country and Regional Abbreviations

Abbreviation Abbreviation Albania ALB Latvia LVA Argentina ARG Lesotho LSO Australia AUS Macedonia, fo rmer Austria AUT Yugoslav Rep. of MKD Belgium BEL Mali MLI Bolivia BOL Mauritania MRT Brazil BRA Mexico MEX Bulgaria BGR Netherlands NLD Canada CAN New Zealand NZL Chile CHL Norway NOR China CHN Pakistan PAK Colombia COL Papua New Guinea PNG Cote d'Ivoire CIV Peru PER Czech Republic CZE Philippines PHL Denmark DNK Portugal PRT Dominican Republic DOM Romania ROM Ecuador ECU Russia RUS Estonia EST Sierra Leone SLE Finland FIN Singapore SGP France FRA Slovak Republic SYK Germany DEU Slovenia SYN Guinea GIN South Africa ZAF Hong Kong HKG Spain ESP India !NO Sweden SWE Ireland IRL Switzerland CHE Israel ISR To go TGO Italy ITA United Kingdom GBR Japan JPN United States USA Kazakstan KAZ Venezuela YEN Korea KOR

477 4 7 8 + Table ofTax Laws Cited

Ta x Laws

Albania SBT Ligj nr. 7679 Per tatimin mbi biznesin e vogel (Law on ALB Small Business Ta x), of Mar. 3, 1993; reprinted in The Albania Law Report (Alba! SH. P. K. Ti rana), Compilation of Legal Acts of Albania as amended, at 49, Oct. 1995 [in Albanian] [English trans.]. Argentina APFI Procedimiento para Ia Aplicaci6n, Percepci6n y ARG Fiscalizaci6n de lmpuestos (Procedures for the Application, Collection and Inspection of Ta xes), Ley N2 11.683, B.O. Dec. 11, 1978 (as amended to 1991 by Law N2 23.905, B.O. Feb. 18, 1991 ); reprinted in 1 Legislaci6n lmpositiva 1991, at 1, La Ley [in Spanish]. IVA lmpuesto al Valor Agregado (Value Added Ta x), Ley N2 23.349, B.O. Aug. 25, 1986 (as amended by Ley N2 23.905, B.O. Feb. 18, 1991) I d. at 383. lA lmpuesto sobre los Activos (Tax on Assets), Ley N2 23.905, B.O. Dec. 18, 1990 (as amended by Ley N2 23.905, B.O. Feb. 18, 1991) I d. at 279; also [English translation] reprinted in TLW at 44 (as amended to Sept. 1993). Australia ITAA Income Ta x Assessment Act 1936; reprinted in lA and IB AUS Australian Income Ta x Legislation (as amended to june 30, 1992) (CCH Australia Limited 1992). CTO Crimes (Taxation Offences) Act 1980; Id. at 72,003. Austria UStG Umsatzsteuergesetz 1972 (Turnover Ta x Law), BGBI 1972/ AUT ZZ3; reprinted in Kodex des Osterreichischen Rechts: Steurrecht (Christoph Ritz ed., 16th ed., LINDE VERLAG WIEN 1993) (as amended to 1993) [in German] [as of Jan. 1, 1995, UStG 1994, BGBI 663]. BAO Bundesabgabenordnung (Federal Fiscal Code), BGBI 1961/ 194; Id. Belgium CIR Code des lmpots sur les Revenus (Income Ta x Code); BEL reprinted in Code des lmp6tssur les Revenus 1992 (Ministere des , Administration des Contributions Directes 1992) (as amended to july 1992) [in French] and 4 TLW [English trans.]. Bolivia IRPE lmpuesto a Ia Renta Presunta de Empresas (Tax on BOL Presumptive Income of Businesses), Ley N2 843 of May 20, 1986; reprinted in 1 Recopilaci6n Tr ibutaria al 31 de diciembre de 1992, at 163 (Direcci6n General de lmpuestos lnrernos 1993) (as amended to Dec. 31, 1992) [in Spanish].

Brazil CTN Lei N2 5.172 C6digo Tr ibutario Nacional (National Ta x BRA Code) of Oct. 25, 1966; reprintedin Editora Saraiva, C6digo Tr ibutario Nacional, at 21 (1990) [in Portuguese].

Note: Tax Laws of the World (Foreign Publishers) is abbreviated as TLW. Tax Notes International is abbreviated as TNI. Laws cited are not necessarily those currently in force at time of publication. Tableof Tax Laws Cited • 479

Bulgaria VAT Zakon za Danak varkhu Dobavenata Stoynost (Law on BGR Value Added Ta x), OfficialGazette, N2 90 of 1993; reprinted in Danachno Oblagane za 1994 Godina 202 (IK "Trud i Pravo" 1995) [in Bulgarian). and [English trans.) from 168 Hours British Broadcasting News (BBN), vol. 3, N� 46 and 4 7, Nov. 15-2 1 and 22-28, 1993. Canada ITA Act, R.S.C. 1985; reprinted in H. Stikeman, CAN Stikeman Income Ta x Act, Annotated (23rd ed., Carswell Thomson Professional Publishing 1994) (as amended to

July 31, 1994). • GST Goodsand Services Ta x provisions contained in the Ta x Act, R.S.C. 1985; reprinted in The Practitioner's Goods and Services Ta x, Annotated (David M. Sherman, ed., 4th ed., Carswell Thomson Professional Publishing 1994) (as amended to Aug. 15, 1994). Chile CT Decreta Ley N2 830 sobre C6digoTr ibutario (Tax Code) CHL D.O. del 31 de diciembre de 1974 y actualizado hasta el 31 de julio de 1994; reprintedin Te xtos Legales, Servicio de lmpuestos lnternos, at 331, Arrayan ed. (1995) [in Spanish]. IR Decreta Ley N2 824 de lmpuesto a Ia Renta (income Tax), D.O. del 31 de diciembre de 1974 y actualizado hasta el 4 de fe brero de 1995; Id. at 9. !HAD Decreta Ley N2 16.271, de lmpuesto a las Herencias, Asignaciones y Donaciones (Inheritance and Law) D.O. del 10 de julio de 1965 y actualizado hasta el 31 de diciembre de 1994; Id. at 571. China VAT Provisional Regulations of the People's Republic of China CHN on Value-Added Ta x, enacted by the State Council on Dec. 13, 1993; reprinted in National Ta xation Bureau, Foreign Ta xation Administration Department, A Collection of Ta x Laws and Regulations of the People's Republic of China, at 102 (State Statistical Bureau 1994) [in Chinese, with English trans.). LT Provisional Regulations of the People's Republic of China on Land Appreciation Ta x, enacted by the State Council on Dec. 13, 1993; Id. at 224. TA The Law of the People's Republic of China Concerning the Administration of Ta x Collection, enacted by the Standing Committee, National People's Congress on Sept. 4, 1992; Id. at 236. Colombia ET Estatuto Tr ibutario (Taxation Statute), Decreta N2 624 (del COL 30 de marzo de 1989); reprinted in Rodrigo Monsalve T., lmpuestos 1991 (renta, ventas e indirectos), at 51 (Centro lnteramericano juridico-Financiero 1991) (as amended to 1991) [in Spanish). 480 • Table of Tax Laws Cited

COte d'Ivoire CGI Code General des lmp6ts 1981 (General Ta x Code); CIV reprinted in Republique de COte d'lvoire, Code General des lmp6ts (Impr. Nationale 1981) (as amended to Dec. 31, 1980) [in French]. Czech Republic IHT Zakon N11 357 Ceske narodnf rady o dani dedicke, dani CZE darovacf a dani z prevodu nemovitostf (Law on , Gift Tax, and Real Estate ); reprinted in Sbfrka zakonu, at 1993 (July 7, 1992) [in Czech]. Zakon N11322 kterym se menf a doplnuje zakon Ceske narodnf rady c N11 357/1992 Sb., o dani dedicke, dani 4arovacf a dani z prevodu nemovitostf, ve znenf zakona Ceske narodnf rady c N11 18/1993 Sb. (Amendments to Law N11 357 on Inheritance Ta x, Gift Ta x, and Real Estate Transfer Tax); reprinted in Sbfrka zakonu, at 1753 (Dec. 30, 1993).

Zakon kterym se doplnuje zakon Ceske narodnf rady c. N11 357/1992Sb., o dani dedicke, dani d�rovacf a dani z prevodu nemovitostf, ve znenf zakona Ceske narodnf rady c N11 18/1993 Sb. zakona c 322/1993 Sb. zakona C. 42/ 1994 Sb. zakona c 85/1994 Sb. (Amendments to Law N" 357 on Inheritance Tax, Gift Ta x, and Real Estate Transfer Ta x); reprinted in Sbfrka zakonu, at 1 162 (July 8, 1994). Denmark INH Arve- og gaveafgiftsloven (Act on Inheritance and Gift DEN Ta x) Lovbekendtg¢relse nr. 62 af 6. fe bruar 1987 om afgift af arv og gave; reprinted in Danske Skattelove 1990/1991 med henvisninger (Peter Ta rnoj ed., NSf Skattekartoteket lnfo rmationskontor 1990) (as amended through July 1990) [in Danish]. Alsoreprinted in 9 TLW, at 89 (as amended to Nov. 1988) [English trans.]. Dominican CT C6digo Tributario de Ia Republica Dominicana (Tax Code Republic of the Dominican Republic); reprinted in C6digoTr ibutario OOM de Ia Republica Dominicana ( 1992 ), Government Publisher [in Spanish] translated in9 TLW (as amended to Nov. 1993) [English trans.]. Ecuador CT C6digo Tr ibutario, Ley N11 55of June 13, 1994; reprinted in ECU Corporaci6nde Estudios y Publicaciones, C6digo Tr ibutario [in Spanish]. Estonia LOT Law on Taxation, RT I 1994, 1, 5; reprinted in Estonian EST 5 (Piret Joalaid ed., Marje Einre trans., AS Vaba Maa 1994) (as amended to Mar. 16, 1994) [English trans.]. IT Income Ta x Law, RT I 1993, 79, 1184; Id. at 26. VAT Law on Value Added Tax, RT I 1993, 60, 84 7; Id. at 49. LND Law on Land Tax, RT 1993, 24, 428; ld. at 69. GAM Law on Gambling Ta x, RT 1992, 35, 458; Id. at 73. France CGI Code General des lmp6ts 1993 (General Ta x Code); FRA reprinted in Code General des lmp6ts (22nd ed., Dalloz 1993) (as amended to May 15, 1992) [in French]. Tableof Tax lAwsCited • 481

LPF Livre de Procedures Fiscales 1992, Ministere du Budget, lmpr. Nationale 1992 [in French]. Germany AO Abgabenordnung 1977 (FiscalCo de), BGBl IS. 613, ber. DEU BGBl 1977 I S. 269; reprinted in Deutsche Steuergesetze 1992, at 12 (4th ed., IDW-Verlag GmBH 1992) (as amended to 1992) [in German]. FVG Gesetztiber die Finanzverwaltung (FVG)(Law on Tax Administration) of Aug. 30, 1971, BGBl IS. 1426;Id. at 235. EStG Einkommensteuergesetz 1990 (income Tax Law), BGBl IS. 1898; Id. at 260. KStG Korperschaftsteuergesetz 1991 (CorporationTa x Law) of Mar. 11, 1991, BGBl I, 639; Id. at 714. UStG Umsatzsteuergesetz 1991 (TurnoverTa x Law) of Feb. 8 1991, BGBl IS. 351; Id. at 784. VStG Vermogensteuergesetz ( Law) ofNov. 14, 1990, BGB1 IS. 2467; Id. at 958. ErbStG Erbschaftsteuergesetz (Inheritance Tax Law) of Feb. 19, 1991, BGBl IS. 469; Id. at 976. StBetG Steuerberatungsgesetz (Tax Advising Law) of Nov. 4, 1975, BGBlIS . 2735; Id. at 1126. Guinea CIDE Code des lmp<)tsDirects d'Etat, 1990. GIN Hong Kong EDO Estate Ordinance, reprinted in Handbookof Hong HKG Kong Tax Statutes (Chapter 111, 1983 rev. ed.), as amended, Butterworths (1990). India IT Income Tax Act, 1961; reprinted in 16 TLW (as amended IND through Act, 1992). Ireland VAT Value Added Ta x Act, 1972; reprinted in Ireland, Office of the IRL Revenue Commissioners, Lawof Value-Added Ta x After Enactment of Finance Act, 1985 on 30 May, 1985 (Stationery Office19 85) (as amended to May 30, 1985). Israel IT Income Tax Ordinance; reprinted in Income Ta x Ordinance, ISR Amendments N� 91 to 94 (A.G. Publications 1993) (as amended to Oct. 1, 1993) [English trans.]. VAT Value Added Ta x; reprinted in 19 TLW (as amended to Apr. 1989) [English trans.]. Japan CTL Consumption Ta x Law; reprinted in Japan-National JPN Law: An English Translation with Cabinet Orders as at Apr. 1, 1989 with an introduction by Prof. Koji Ishimura (CCH lntemational 1989) [English trans.]. IHT Law N2 7 3 The Inheritance Tax Law of Mar. 31, 1950; reprinted in The Inheritance Ta x Law of Japan, IV EHS Law Bulletin Series, Eibun-Horei-Sha, ed. (as amended to Mar. 1975) (1975) [English trans.]. 482 • Table ofTax LawsCited

Kazakstan TC Ukaz 0 Nalogakh i Drugikh Obyazatel'nykh Platezhakh v KAZ Byudzhet (Decree Concerning Ta xes and Other Compulsory Payments to the Budget of Apr. 16, 1995) (Tax Code); reprinted in 0 Nalogakh i Drugikh Obyazatel'nykh Platezhakh v Byudzhet: Ukaz Prezidenta Respubliki Kazakstan, imeyushchiy silu zakona (Karzhy-karazhat 1995) [in Russian]. Also 95 TNI 84-16 (doc. 95-20820 and doc. 95-20614) [English trans.]. Korea BNTA Basic National Tax Act, Law N2 2679 Dec. 21, 1974 (as KOR amended to Dec. 31, 1993 ); reprinted in Korean Legal Center, 2 Laws of the Republic of Korea, 4th ed. [English trans.]. Latvia TF Law on Ta xes and Fees, Feb. 2, 1995, 95 TNI 70-20, doc. LVA 95-2044 [English trans.].

ET Law on Excise Tax of Dec. 1990, as amended to Mar. 1995 [unpublished English trans.]. EIT Law on Enterprise Income Ta x, Feb. 9, 1995, 95 TNI 64-26, doc. 95-20442 [English trans.]. Lesotho IT Income Ta x Order 1993, 38 Lesotho Government Gazette LSO Extraordinary N2 33, at 403, amended by Income Tax (Amendment) Act 1994, 39 Lesotho Government Gazette Extraordinary N2 54, at 552. Macedonia, PPT Law on Property Ta x, Ministry of Finance, as updated to former Yugoslav Dec. 30, 1993 [English trans.]. Rep. of MKD Mali CGI Code General des lmp6ts (General Ta x Code); reprinted in MLI Code General des lmp6ts (Editions du Cabinet de Conseil Fiscal 1991) (as amended to Dec. 31, 1991) [in French]. Mauritania CGI Code General des lmp6ts (General Ta x Code); reprinted in MRT Mauritania, Ministere des Finances, Code General des lmp6ts, mise a jour: Loi de Finances 1990 (Ministere des Finances 1990) [in French]. Mexico CF C6digo Fiscal de Ia Federaci6n 1988 (Federal Ta x Code); MEX Secretarfa de Hacienda y Credito Publico [in Spanish] (1988). AT L Ley del lmpuesto al Activo (Assets Tax Law), Diario Oficial,Dec. 31, 1988, Cap 5, Art. 10 de Ia ley que establece, reforma, adiciona y deroga diversas disposiciones fiscales, vigente a partir del 12 de enero 1989 [in Spanish]. Netherlands Vpb Vennootschapsbelasting 1969 (Corporation Income Tax NLD Law); reprinted in Belastingwetgeving 1995, at 158 (Koninklijke Vermande) (as amended to 1994 [in Dutch]. AW R Algemene wet lnzake Rijksbelastingen 1959 (General Ta x Code), Stb. 301; I d. at 498. Tableof Tax LawsCited + 483

New Zealand GST Goodsand Services Ta x Act; reprinted in Goods and NZL ServicesTa x Legislation (5th ed., Commerce Clearing House New Zealand Limited 1990) (as amended to Sept. 1, 1990). EGD Act N2 35 Estate and Gift Duties, Nov. 25, 1968; reprinted in Statutes of New Zealand, New Zealand Government, 1979. Norway Aal Arveavgiftloven (Lov om avgift p11 arv og visse gaver av. 19 NOR juni. 1964 nr. 14) (Inheritance Duty Act). Papua WPA Wills, Probate, and Administration Act N2 68 of 1967, as New Guinea amended to Jan. 1980; reprinted in 10 The Revision of Laws, PNG Independent State of Papua New Guinea, 1980. Peru CT Decreta Supremo N2 395-82-EFC C6digoTr ibutario PER (Supreme Decree: Tax Code), El Peruano, 6 de enero de 1983; reprinted in C6digo Tr ibutario, Ministerio de Economfa y Finanzas, Direcci6n General de Contribuciones (1985). Philippines NIRC National Internal Revenue Code of 1977; reprinted in The PHL National Internal Revenue Code of the Philippines, as amended by R.A. N� 7496, 7497, and 7499 (Jose N. Nolledo ed., National Bookstore, Inc. 1992) (as amended to 1992). Portugal CIVA C6digo do Impasto sabre o Valor Acrescentado (Value PRT Added Tax Code), Decreta-Lei N2 394-B/84 de 26 de dezembro; reprinted in C6digo do Impasto sabre o Valor Acrescentado (Rei dos Livros 1984) [in Portuguese). lSD C6digo da Sisa e do Impastosabre as Sucessoes e Doa�oes (Transfer, Succession and Gift Ta x Code) Decreta-Lei N2 41 969, de 24 de novembro de 1958; reprinted in C6digo da Sisa e do Impasto sabre as Sucessoes e Doa�oes, Rei dos Livros sa ed. (as amended to 1987) [in Portuguese].

Romania PT Ordonanta privind lmpazirul pe Profit (ProfitTa x Law), ROM Monitorul Oficial al Romaniei, Aug. 31, 1994 [in Romanian). Russia TS Law N2 2118-1 of the Russian Federation of Dec. 2 7, 1991 RUS Concerningthe Fundamental Principles of the Ta xation System in the Russian Federation [English trans. by Ernst & Young) (as amended through Federal Law N2 9-FZ of the Russian Federation ofjuly I, 1994). STS Zakon Rossiyskoy Federatsii "0 gosudarstvennoy nalogovoj sluzhbe RSFSR"(s izmeneniyami i dopalneni­ yami na 25 Fevralya 1993 goda) or 3/21/91 N 943-1 (Law of the Russian Federation "On the State Ta x Service of the RSFSR" (with amendments to Feb. 25, 1993)). Prinyat Verkhovniy Saver Rossiyskoy Federatsii Data redaktsii 2/25/93. Vedomosti S'ezda narodnykh deputatov RSFSR i Verkhovnogo Soveta RSFSR, 1991, N15, st. 492. 484 • Table of Tax LawsCited

IT Law of the RSFSR on Income Tax fromPhys ical Persons; reprinted in "Vse Nalogi Rossii," Feb. 1992, at 17-35 [in Russian];translated in FBIS-USR-92-01 0-L, Sept. 17, 1992, at 32-43[English trans.]. Lawof the RussianFed eration Concerning Income Tax from Physical Persons[En glish trans. by Ernst & Young] (as amended by the law of the Russian Federation of July 16, 1992 ConcerningAmend­ ments and Additions to the Ta xation System of Russia). IHT Act N112020-1 RussianFederation Tax on Property Transferred by Inheritance or Gift Act, Mar. 1993; reprinted in 2 Business and Commercial Laws of Russia: Business Enterprises, Privatization, Commercial Tr ade, McGraw-Hill [English trans.].

PT Law of the RSFSR on Income (Profit)Ta x from Enterprises; reprinted in "Rossiyskaya Gazeta," Mar. 12, 1992, at 3 [in Russian]; translated in FBIS-USR-92-054, May 5, 1992, at 20-2 7 [English trans.]. Law N1121 16-1 of the Russian Federation of Dec. 2 7, 1991, ConcerningTa x on the Profit of Enterprises and Organizations [English trans. by Ernst & Young] (as amended through LawN11 54-FZ of the Russian Federation of Dec. 3, 1994 Concerning the Introduction of Amendments and Additions to the Law of the Russian Federation ConcerningTax on the Profitof Enterprises and Organization). Federal Law N1164-FZ of the Russian Federation of Apr. 25, 1995, Concerning the Introduction of Amendments and Additions to the Law of the Russian Federation Concerning Ta x on the Profit of Enterprises and Organizations [English trans. by Ernst & Young]. TA E Law N112030- 1 of the Russian Federation of Dec. 13, 1991, ConcerningTa x on the Assets of Enterprises [English trans. by Ernst & Young] (as amended through Federal Law N11 37-FZof the Russian Federation of Nov. 11, 1994, Concerningthe Introduction of Amendments and Additions to Certain Ta x Laws of the Russian Federation and Concerningthe Establishmentof Exemptions in Relation to Compulsory Payments to State Non-Budgetary Funds). VAT Law N11 1992-1 of the Russian Federation of Dec. 6, 1991, ConcerningVa lue Added Tax; reprinted in "Ekonomicheskaya Gazeta" N11 1, Jan. 1992 [in Russian); [English trans. by Ernst & Young] (as amended through Federal Law N11 54-FZ of the Russian Federation of Dec. 6, 1994, Concerning the Introduction of Amendments and Additions to the Law of Russian Federation Concerning Value Added Tax). Federal Law N1163-FZ ofthe Russian Federation of Apr. 25, 1995, Concerning the Introduction of Amendments and Additions to the Law of the Russian Federation Concerning Value Added Ta x [English trans. by Ernst & Young]. Table of Tax Laws Cired • 485

Sierra Leone IT Income Ta x Act, N11 1 of 1943, ch. 273; reprinted in The SLE Income Tax Act (as amended to Dec. 31, 1992) (unofficial consolidation). Singapore GST Act N1131 of 1993, The Goodsand Services Ta x Act 1993; SGP reprinted in Singapore,Government Gazette Acts Supplement, N11 28, 1993. ED Act N11 19 of 1931 EstateDuty Act, as amended through Act N11 14 of 1984, Cap. 96; reprinted in The Statutes of the Republic of Singapore, Government Printer, 1985 rev. ed. Slovak TAL Zakon o danovych poradcoch a Slovenskej Komore Republic danovych poradcov (Law on Ta x Advisers and the Slovak SVK Chamber of Tax Advisers) N11 78, Jan. 29, 1992, 1992 zb. castka 20, strana 507 [in Slovak]. INH Zakon o Dani z Dedicstva, Dani z Darovania a Dani z Prevodu a Prechodu Nehnutefnostf (Law on Inheritance Ta x, GiftTa x and the Ta x on the Transfer of Real Property), Zakon Slovenskej narodnej rady c.318/1992 Zb. of May 4, 1992; reprintedin Sustava Danf a Poplatkov od roku 1993, at 79 (Ing. )ozefTorjak, CSc.a kolektiv 1993) [in Slovak]. Slovenia TC Zakon o davkih oocanov (Law of Tax on Citizens) of Sept. SVN 28, 1988, Official Gazette Uradni List N11 36 of Oct. 21, 1988, as amended by Law N11343 OfficialGazette N118, Mar. 3, 1989, and Law N11 300Official Gazette N11 7 of Feb 4, 1993 [in Slovenian]. South Africa VAT Act N11 89 Value Added Ta x Act, 1991, Government ZAF Gazette N11 13307 of june 12, 1991. Spain LGT Ley General Tr ibutaria (General Ta x Law), B.O.E. del 31 de ESP diciembre de 1963; reprinted in 1 Leyes Tr ibutarias, Legislaci6n Basica 27 (5th ed., Spain, Ministerio de Economfa yHacienda 1993) (as amended to Dec. 30, 1992) [in Spanish]. IRPF Ley 18/1991, del 6 de junio, del lmpuesto sobre Ia Renta de las Personas Ffsicas (Personal Income Tax Law), B.O.E. del 7 de junio y del 2 de octubre de 1991; Id. at 469. IS Ley 61/1978, del 27 de diciembre, del lmpuesto sobre Sociedades (CorporationTax Law), B.O.E. del 30 de diciembre de 1978; Id. at 655. IP Ley 19/1991, del 6 de junio, del lmpuesto sobre el Patrimonio (Law Governing Wealth/PropertyTa x), B.O.E. del 7 de junio y del 2 de octubre de 1991; Id at 883. lSD Ley 29/1987, del lS de diciembre, del lmpuesto sobre Sucesiones y Donaciones (Law Governing the Tax on Bequestsand Gifts), B.O.E. del 19 de diciembre de 1987; Id. at 911. IVA Ley 37/1992, del 28 de diciembre, del lmpuesto sobreel Valor Aftadido (Value Added Tax), B.O.E. del 29 de diciembre de 1992, B.O.E del 8 de febrero de 1993; Id. at 1113. 486 • Table ofTax Laws Cited

Sweden AAR Act on Advance Rulings in Questions Relating to Tax SWE Assessment ( SFS 19 51 :44 2) [English trans.). SF Lag upphavande av lagen (194 7: 577) om statlig fo rmi:igenhetsskatt (1991:1850) (Law (1991:1850) repealingLaw on State Wealth Tax); reprinted in Skatte-och taxerings-orfattringarna (Skattefi:ivaltningen, Riksskatterverket (as amended to Jan. 1, 1992) at 463 [in Swedish]. Lag om statlig formi:igenhetsskatt (Law ( 194 7:577) on State Wealth Ta x); ld. AGL Lag om arvsskatt och g�voskott, 1941 (Law on Inheritance and Gift Ta x). Switzerland OTVA Ordonnance n!gissant Ia taxe sur Ia valeur ajoutee (Value CHE Added Tax) of June 22, 1994; reprinted in 6(2) Recueil Systematique du Droit Federal, at 64 1.201. To go CGI Code General des lmpots (General Tax Code); reprinted in TGO Ministere de I'Economie et des Finances, Code General des lmpats (1985) [in French). United TMA Taxes Management Act 1970; reprinted in Great Britain, Kingdom Boardof Inland Revenue, 1 The Taxes Acts: Income Tax, GBR Corporation Tax and (HMSO 1994) (as amended to 1 994). ICTA Income and Corporation Ta xes Act 1988; reprinted in Great Britain, Board of Inland Revenue, 1 and 2 The Ta xes Acts: Income Ta x, Corporation Ta x and Capital Gains Ta x (HMSO 1994) (as amended to 1994). VAT Value Added Tax Act 1994; reprinted in The Law Reports Statutes 1994, pt. 5, The Incorporated Council of Law Reportingfo r England and Wales, Cap. 23, at 1393. IHT Inheritance Ta x of 1984; reprinted in 43 Halsbury's 1068 and Orange Ta x Handbook, Butterworths, 1995-96, at 46. United States IRC Internal Revenue Code; reprinted in The Complete Internal USA Revenue Code: All the Income, Estate, Gift, Employment, Excise, Procedure and Administrative Provisions (Research Institute of America, Inc. 1995) (as amended to Dec. 31, 1994 ). Venezuela COT C6digo Organico Tr ibutario (General Tax Code), G.O. N2 YEN 2.992 Extraordinario del 3 de agosto de 1982 [in Spanish). IR Ley de lmpuesto sabre Ia Renta (Income Tax Law), Gaceta Oficialde Ia Republica de Venezuela of Sept. 9, 1993 [in Spanish); reprinted in 45 TLW (as amended to Dec. 1993) [English trans.]. Decreta N2 3113 Ley de Reforma Parcial de Ia Ley de lmpuesto sabre Ia Renta (Law on the Partial Reform of the Income Ta x Law), del 26 de agosto de 1993, Gaceta Oficial N2 4.628 Extraordinario del 9 de septiembre de 1993 [in Spanish). Tableof Tax LawsCited + 487

AT L Decreto N" 3.266 Ley de lmpuesto a los Activos Empresariales (Law on the Ta x on BusinessAssets ), del 26 de noviembre de 1993, Gaceta Oficial deIa Republica de Venezuela N" 4.654 of Dec. 1, 1993 [in Spanish). IC Decreto que Establece el lmpuesto a! Consumo Suntuario y a las Ventas a! Mayor (Decree Establishing a Ta x on Luxury Consumption and Sales at Wholesale), Gaceta Oficialde Ia Republica de Venezuela of May 27, 1994 [in Spanish).

Biographical Sketches

EDITOR

Victor Thuronyi received his undergraduate degree in eco­ nomics from Cambridge University and his law degree from Harvard Law School. He has practiced tax law, served in the Officeof of the U.S. Treasury Department in 1983-86, and was thereafter associate professor of law at SUNY-Buffalo Law School until joining the Legal Depart­ ment of the IMF in 1991. Mr. Thuronyi, who currently serves as Senior Counsel (Taxation) of the Fund, has partic­ ipated in many staffmissions involving legislative drafting and advice on taxation laws of member countries of the Fund. He is the author of several articles on taxation and a coauthor of The Ta xation of Income from Business and Capital in Colombia (Duke University Press, 1990).

AUTHORS OF CHAPTERS

Lee Burns has degrees in law and commerce from the Uni­ versity of New South Wales and a master of laws from the University of Sydney. Mr. Burns is a senior lecturer in the faculty of law, University of Sydney, where he teaches taxa­ tion law in both undergraduate and postgraduate programs. He has acted as consultant to the Legal Department of the IMF and to the Australian Taxation Office, and has taught in OECD-sponsoredcourses in Moscow. He is a coauthor of AustTalian Ta..xation Law {into its sixth edition) and the author of ContTol/.edForeign Companies: Taxationof Foreign Source Income.

Sijbren Cnossen is a professor in the economics faculty of Erasmus University, Rotterdam, where he teaches public finance and tax law. Prior to his appointment in 1977, he was a staff member of the IMF.Dr. Cnossen is the author or editor of several books and has written numerous articles on tax policy. He has lectured widely at fo reign universities and research institutes and has advised many governments on the design of their tax systems. Dr. Cnossen is editor of International Ta x and

489 490 + Biographical Sketches

Public Finance as well as De Economist. He is also a concurrent judge on the Dutch tax court.

Graeme Cooper is an associate professor of law at the University of Sydney, where he specializes in taxation law and policy. He is currently on leave from the university to work in the Fiscal Affairs Division of OECD, Paris, in the Unit for Cooperation with Economies in Transition and Non-Member Countries. His work with OECD involves providing advice and training to officials from the govern­ ments of emerging market economies in Eastern Europe and Central Asia. He has also worked as a consultant to the IMF and as a member of various advisory committees to the Australian Government and the Australian Taxation Office. He has studied and taught at universities in Australia and the United States and is the author of several books on taxation as well as many articles in Australian and international journals.

Alexander Easson is a professor of law at Queen's Uni­ versity, Kingston, Ontario, Canada. He studied at Oxford University and the London School of Economics, prac­ ticed tax law for some years in London, and taught at the University of Southampton, before moving to Canada in 1976. Mr. Easson has been a visiting professor at univer­ sities in Australia, China, Germany, and Italy. He has participated in Fund missions to countries in Africa and has worked as a consultant with the OECD in Central and Eastern Europe. He is the author of several articles and books on taxa­ tion, the most recent being Ta xation in the European Community (Athlone Press, 1993).

Richard Gordon has been an advisor to the Legal Depart­ ment of the IMF since 1995. After graduating from Yale University and Harvard Law School, he practiced law at the firm of Dewey Ballantine and taught at the School of Oriental and African Studies at the University of London. In 1990, he became deputy director of the Harvard Inter­ national Ta x Program and an associate at the Harvard Institute for International Development, and in 1991 became lecturer in law at the Harvard Law School. Mr. Gordon has participated in many tax and economic reform projects in devel­ oping and transition countries and is the author of a number of articles on taxation and on law and development. He is one of the world's finest practi­ tioners of Punjabi cooking. Biographical Sketches + 491

David Holland received a master's in science in mathe­ matical economics and econometrics from the London School of Economics. After teaching there and at Dal­ housie University, he joined the Ministry of Finance in the Canadian Government, where during the course of a career spanning 17 years he held a variety of senior pol­ icy positions, including Director of Business Ta xation and General Director of the Tax Policy Branch. In these positions, he was intensively involved in the reform of the Canadian tax system. In 1993, he joined the OECD's Unit for Coopera­ tion with the Economies in Transition and Other Non-Member Countries, which he currently directs.

Rick Krever holds a law degree from Osgoode Hall Law School and a master's in law from Harvard Law School. Formerly a reader at Monash University, Professor Krever was appointed to a chair at Deakin University in 1993, where he teaches in the school of law and acts as director of the university's Taxation Law and Policy Research Institute. Professor Krever served as a visiting consultant to the IMF in 1994 and has participated in Fund missions providing taxation law drafting advice to a number of member countries. He has also acted as a consultant to the treasuries of Australia and New Zealand and is currently a member of a consultative committee advising the Australian Government on the redrafting of that country's income tax legislation. Professor Krever's published works include a taxation law casebook, Income Ta xation Com­ mentary and Materials, of which he is a coauthor (Law Book Company, 1989 and 1993) and a taxation law and policy text, Australian Ta xation: Principles and Practice, of which he is the editor and a contributor (Long­ man, 1987).

Rebecca S. Rudnick received her undergraduate degree in economics and English from Willamette University, her law degree from the University of Texas School of Law, and a master's degree in tax law from New York University School of Law. She has practiced tax law in New York City, served as special counsel to the New York State Legislative Tax Study Commission and as professor-in-residence in the Office of Chief Counsel of the U.S. Internal , and has taught tax law at a number of U.S. law schools since 1985. Professor Rudnick, who is currently visiting at the University of Pennsylvania Law School, has partic­ ipated in legislative drafting and advising on developing and transition 492 + BiographicalSketches economy tax laws for the IMF Legal Department. She is the author of sev­ eral articles on taxation and is active in many tax organizations. During the academic year 1996-97, she will be visiting professor of law at Seattle Uni­ versity School of Law.

Ben J.M. Terra studied international law at the Uni­ versity of Amsterdam and (indirect) taxation at the University of Leyden. He has written a thesis on VAT on cross-border transactions. Professor Terra was a head of postgraduate training in VAT, , and at the Ministry of Finance in The Hague; professor of law at the University of Leyden; and visiting professor at the University of Florida in Gainesville and the Univer­ sity of Sydney in Australia. He is a professor of law at the University of Amsterdam, a partner at Moret Ernst & Young Tax Advisers in Amsterdam, cochairman of the E&Y European VAT group, and editor-in-chief of the International VAT Monitor and a biweekly indi­ rect taxation magazine in the Netherlands. He has published numerous articles and books on indirect taxation, including A Guide to the European VAT Directives (Terra/Kajus, IBFD, a five-volume loose-leaf publication updated quarterly) and A Guide to the Community Customs Law (Kluwer, 1995 ).

Koenraad van der Heeden received his undergraduate degree in economics and his Ph.D. (in 1973) from Eras­ mus University, Rotterdam, and taught fiscal economics for several years at this university. Mr. van der Heeden worked until 1991 at the Dutch Ministry of Finance, where he was in charge of the tax policy and interna­ tional fiscal affairs departments. In 1991, he joined the Fiscal Affairs Department of the IMF and has provided technical assistance in tax policy and tax administration to numerous countries.

Frans Vanistendael studied law and economics at K.U. Leuven in Belgium and received a master's in law from Yale. He is a professor of taxation at K.U. Leuven and a member of the Brussels bar. He was Royal Commis­ sioner of in Belgium (1987-88) and a mem­ ber of the Ruding Committee on European (1991-92). Mr. Vanistendael has partic­ ipated in Fund missions to Eastern European countries and China and has worked as a consultant in tax admin­ istration with the OECD. Biographical Sketches • 49 3

Richard Vann is a professor of law at the University of Sydney, where he has taught fo r 20 years mainly in inter­ national and corporate taxation. From March 1990 to February 1991, he worked as Counsel (Taxation) in the Legal Department of the lMF,draf ting tax laws for devel­ oping and transition countries. From September 1992 to January 1995, he was head of Central and Eastern Europe and NIS Programme, Fiscal Affairs Division, OECD, where he ran a technical assistance program fo r countries in this region. He currently acts as a consultant to the IMF, the OECD, the Australian Ta xation Office, and Greenwoods & Freehills, Taxation Consul­ tants, Sydney. He is a member of the Global Law Faculty of New York Uni­ versity. Professor Vann is editor of Australian Ta x Forum and a governor of the Australian Ta x Research Foundation. He has previously served on the Ta xa­ tion Committee of the Law Council of Australia and the N.S.W. State Coun­ cil of the Ta xation Institute of Australia. He has edited and published several books on taxation, including Company Ta x Reform , Income Ta xation Commen­ tary and Materials , Trans-Tasman Taxation of Equity Finance , and Measuring Income Under Inflation. Over the years he has published many articles in all areas of taxation.

David Williams holds a master's degree in law and a doc­ torate in philosophy from the University of Bristol. He is a solicitor of the Supreme Court of England and Wales and an associate of the Chartered Institute of Ta xation. He holds the professorship in tax law at the Centre for Com­ mercial Law Studies, Queen Mary and Westfield College, University of London. Mr. Williams has been involved in fo r over a decade as an academic and in working for the IMF, the OECD, the EU, and gov­ ernments. His publications include Trends in International Ta xation (1991), The National Insurance Contributions Handbook (loose-leaf), and a range of other books and articles for both professional and popular readerships.

Joan Youngman received her undergraduate degree in socialstudies from Harvard University and her law degree from Harvard Law School. She has practiced tax law with the Boston firm of Hale and Dorr and served as a research associate at the Harvard Law School International Tax Program, where she is currently a research fe llow. Since 1990, she has held the position of senior fe llow with the Lincoln Institute of Land Policy in Cambridge, Massachu­ setts. Ms. Youngman has participated in international missions for the Fund and for USAID involving legislative drafting and 494 • BiographicalSketches advice on laws concerning land and building taxation. She has helped develop and present courses on the interaction of land policy and taxation fo r the OECD multilateral tax training centers. She is the author of several arti­ cles on taxation, coauthor of An International Survey of Ta xes on Landand Buildings (Kluwer, 1994 ), and author of Legal Issues in Property Valuation and Ta xation (International Association of Assessing Officers, 1994 ).

Eric Zolt is a professor at the University of California, Los Angeles School of Law. He received his undergraduate degree in economics from the Wharton School, Univer­ sity of Pennsylvania, and his graduate business degree and law degree from the University of Chicago. Before joining UCLA, he was a partner in the Chicago law firmof Kirk­ land & Ellis. Professor Zolt served in the Office of Tax Policy, U.S. Department of Treasury from 1989 through 1992, first as Deputy Ta x Legislative Counsel and then as the Director of Treasury's Ta x Advisory Programme for Central and Eastern Europe and the Former Soviet Union.