United Kingdom Tax News
The Australian Taxation Office (ATO) released for comment Draft Taxation Determination ATO TD 2008/D15, which considers the Australian (and UK) taxation consequences of paying and receiving a return under an enhanced bond investment by an Australian taxpayer from a UK bank. The Draft Determination was released on 24 October 2008 and comments are invited by 21 November 2008.
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
Protocol to treaty between UK and Switzerland – signed and details
2001 treaty between United States and United Kingdom – IRS issues interpretation of Art. 18 (Pension Schemes)
Protocol to treaty between New Zealand and United Kingdom enters into force
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 UK and Saudi Arabia ratified
Treaty between UK and Slovenia ratified
Protocol to treaty between UK and New Zealand ratified
Discussion draft on New Art. 7 of OECD Model – details
Netherlands
Treaty negotiation priorities announced
Finance Act 2008 receives Royal Assent
OECD Council approves 2008 Model Tax Convention
Financial Court of Düsseldorf rules on transfer pricing adjustments
Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax
Treaty between France and United Kingdom – details
Exchange of information agreement between United Kingdom and Bermuda – ratified and details
Treaty between United Kingdom and Slovenia – details
Implementation of Mergers Directive
2008 treaty between France and United Kingdom signed
Comments on draft contents of 2008 update to Model Tax Convention published
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)
European Commission closes infringement procedure against Luxembourg 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
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