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1. Introductory
A major part of article no. 148 dealt with the draft version of a directive on loss utilisation released by the Federal Ministry of Finance in the summer of 1998. As reported briefly in article no. 171, the final version of this directive was issued by the tax authorities in April 1999 (directive IV C 6 - S 2745 - 12/99 dated 16 April 1999, hereinafter "the directive").
Large parts of the final version of the directive are identical to the draft version. However, there are also a number of significant changes. This article attempts to identify and comment on the major differences between the draft and final versions of the directive. It is emphasised that the directive represents the position of the tax authorities. It does not possess the force of law and may be challenged in court. Even where this article does
