Hungary Tax News
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details
Hungarian implementation of EU Directive on Cross-Border Mergers of Limited Liability Companies
European Commission takes steps against Belgium for failure to adopt implementing measures of Merger Directive
European Commission takes steps against Germany, Estonia and Czech Republic regarding taxation of outbound dividends
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law
ECJ: Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital – details
OECD released discussion draft on transactional profit methods
ECJ: Advocate General finds the 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Tax Bill for 2008 enters into force
European Commission issues communication regarding accession of Bulgaria and Romania to Arbitration Convention
ECJ:Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital
ECJ: German transitional rules for taxation of capital gains incompatible with EC free movement of capital
Communication published on application of anti-abuse measures in area of direct taxation – within the EU and in relation to third countries
Proposed Hungarian tax bill for 2008 – Part I
ECJ: hearing in case regarding transitional rules in respect of abolished German imputation system
ECJ: Advocate General finds Swedish legislation limiting the exemption of third-country dividends justifiable restriction on EC free movement of capital – details
Compatibility of exclusion of indirect ownership through companies in other EU Member States for French tax consolidation purposes with freedom of establishment referred to ECJ
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details
EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends
Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
ECJ: Finnish group contribution regime compatible with EC Law – details
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
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