Ireland Tax News
Treaty between Ireland and Chile enters into force
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 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
Treaty between Chile and Ireland approved by Chilean Congress
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
Comments on draft contents of 2008 update to Model Tax Convention published
Treaty between Thailand and Ireland – negotiations
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
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
Treaty between Australia and Ireland – ATO: Irish Common Contractual Fund not treaty resident
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
Finance Act 2008 signed into law
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax
Finance Bill 2008 – details
Treaty between Ireland and Vietnam signed
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
Finance Bill 2008 published
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details
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
Unify Your Processes
Simplify Compliance
Empower Your Team