Netherlands Tax News
Preliminary ruling requested from ECJ on interpretation of EC Parent-Subsidiary Directive with respect to Italian tax on dividend adjustment (General Beverage)
Treaty between UK and Netherlands – details
OECD released 2008 Model Tax Convention
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
Netherlands
Treaty between India and Netherlands – Indian decision on applicability of treaty with regard to additional tax imposed for not complying with transfer pricing rules
Hague Court of Appeal – EC free movement of capital: In transactions with Netherlands, Netherlands Antilles is third country not overseas territory
Discussion draft on New Art. 7 of OECD Model – details
Treaty between Netherlands and Barbados – re-negotiation of Art. 10
New Decree on avoidance of double taxation under tax treaties published
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
Protocol to treaty between Netherlands and South Africa signed and details
Protocol to treaty between Netherlands and Estonia signed and details
Treaty between India and Netherlands – Indian decision on taxability of payments for data collection and preparing reports
Treaty between France and Netherlands – French Administrative Court of Appeal finds withholding taxes applied to Dutch pension funds contrary to treaty non-discrimination clause and EU free movement of capital
Financial Court of Münster holds rules on transfer pricing incompatible with EC law
Treaty between the Netherlands and Qatar – details
Comments on draft contents of 2008 update to Model Tax Convention published
Treaty between Germany and the Netherlands – Germany's Federal Financial Court rules on qualification of dividends from third countries paid to Dutch PE of German GmbH
Treaty between Canada and the Netherlands – Tax Court of Canada Prévost decision on "beneficial owner" – details
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
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
Treaty negotiating priorities for 2008
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
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 the Netherlands and Qatar signed
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