Italy Tax News
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
Netherlands restriction on loss compensation under transitional regime compatible with treaty between Netherlands and Italy, EC fundamental freedoms, ECHR Treaty
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
FTC available for withholding tax levied on interest from black listed country
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
Ruling on circumstances under which an internet server constitutes a PE
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
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: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
International tax conference on CCCTB held in Berlin
Italian tax authorities interpret application of Art. 15 of EU-Swiss Agreement
Italian tax authorities issue ruling re treatment of Italian PE of UK partnership, income paid by UK partnership to Italian partners
Legislative Decree amending Parent-Subsidiary Directive published in Official Gazette
Revised Commentary on Article 7 of OECD Model released
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
Final Report on Improving the Resolution of Tax Treaty Disputes
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
Finance Bill 2007 adopted: highlights on corporate taxation
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
Report on Attribution of Profits to PEs released
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
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