Poland Tax News
Protocol to treaty between Poland and Austria signed
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
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
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 – details
Communication published on application of anti-abuse measures in area of direct taxation – within the EU and in relation to third countries
ECJ: German transitional rules for taxation of capital gains incompatible with EC free movement of capital
ECJ:Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital
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: Finnish group contribution regime compatible with EC Law – details
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
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
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
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
Rulings regime amended
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
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
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
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