Poland Tax News
ECJ: Cobelfret extended to domestic situations and potentially to dividends received from third countries
ECJ finds Finnish dividend withholding tax regime incompatible with EC freedom of establishment
European Commission refers Germany to ECJ over taxation of outbound dividends
Treaty between Qatar and Poland ratified
Treaty between Qatar and Poland signed
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
Protocol to treaty between Austria and Poland approved by Austrian parliament
OECD Council approves 2008 Model Tax Convention
Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax
Comments on draft contents of 2008 update to Model Tax Convention published
New tax treaty between Poland and Finland – negotiations
Protocol to treaty between Poland and Austria approved by Polish parliament
Implementation of EC Directive 2005/56/EC on Cross-Border Mergers
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)
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
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 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
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
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