Norway Tax News
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
Proposal to introduce transfer pricing reporting and documentation rules – details
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
Proposed rules on documentation
International tax conference on CCCTB held in Berlin
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Revised Commentary on Article 7 of OECD Model released
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
Treaty between India and Norway – withholding tax rates reduced
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
Final Report on Improving the Resolution of Tax Treaty Disputes
Report on Attribution of Profits to PEs released
Amendments to domestic rules on avoiding double taxation (unilateral relief)
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
Time limits for going to court for tax paid in error – reclaim of Norwegian dividend tax
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
Helicopter is large enough to be a PE
Protocol to treaty between Norway and Austria enters into force
Amendments to CFC rules
Budget for 2007 – details
Treaty between Norway and Australia
Treaty between Australia and Norway – details
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
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