Finland Tax News
ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies resident in other Member States justifiable restriction on EC freedom of establishment – details
ECJ: Advocate General finds Belgian withholding tax on interest paid to companies resident in other Member States compatible with EC freedom of establishment – details
Preliminary ruling requested from ECJ regarding Belgian anti-abuse provision concerning exceptional and gratuitous advantages
Preliminary ruling requested from ECJ on interpretation of EC Parent-Subsidiary Directive with respect to Italian tax on dividend adjustment (General Beverage)
ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies in other Member States justifiable restriction on EC freedom of establishment
OECD released 2008 Model Tax Convention
Discussion draft on New Art. 7 of OECD Model – details
Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax
OECD Council approves 2008 Model Tax Convention
New tax treaty between Poland and Finland – negotiations
Comments on draft contents of 2008 update to Model Tax Convention published
ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details
ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment
ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital
European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case
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 German rules on taxation of cross-border dividends under old imputation system compatible with EC law
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 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details
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
Protocol to treaty between United States and Finland enters into force
European Commission issues communication regarding accession of Bulgaria and Romania to Arbitration Convention
ECJ: Advocate General finds the 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Treaty between Qatar and Finland – negotiations
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