Conversion of preference shares into ordinary shares through mandatory conversion pursuant to the terms of the articles of association is not regarded as a taxable sale according to an
advance tax ruling decided by the Swedish Council for
Advance Tax Rulings on November 7, 2008, which was upheld by the Swedish Supreme Administrative Court in a judgment on May 14, 2009.
Starting with 1991 this board has been transformed into a semi-judiciary independent body named the Council of
Advance Tax Ruling.
The changes include the introduction of a formal
advance tax ruling procedure and a step up opportunity on certain conversions of a corporation into a partnership but eliminating at the same time a loophole in the international participation exemption.
The strategic disadvantages of applying for an
advance tax ruling are shown usually to outweigh the strategic advantages of such a request.
The designation is obtained by requesting an
advance tax ruling.
Finnish-Swedish IT company TietoEnator Corporation said on Tuesday (6 July) that it had received an
advance tax ruling regarding the parent company asset write-downs booked and announced on 21 April 2004.
FEE's Code of Conduct group on business taxation debated a number of
advance tax ruling procedures on August 28, when considering harmful tax practices.
The request was for an
advance tax ruling on their plans to move over $2 billion of assets to the US.
The personnel on the general audit team are the experts on understanding the taxpayer's facts and are in the best position to confirm that the facts are consistent with the representations in the
advance tax ruling request.
On March 8, 1991, a law firm acting for a family trust asked Revenue Canada for an
advance tax ruling to verify that public company shares held within the trust could leave Canada on a tax-free basis.
Assuming that the proposal is approved on the general meetings and that a final
advance tax ruling on the tax issues is received, stating that the reduction of the differences in voting rights to 10:1 and the conversion from B- to A-shares do not trigger tax liability, the proposal will be submitted for resolution at an extraordinary general meeting in Ericsson.
Furthermore, the proposal is subject to that a final
advance tax ruling from the Council for
Advance Tax Rulings (Skatterattsnamnden)/the Supreme Administrative Court (Regeringsratten) has been received, stating that the reduction of the differences in voting rights to 1:10 and the conversion from B- to A-shares, do not trigger tax liability.
