United Kingdom Tax News
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Corporation tax – interest rates
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax
Budget for 2008-09 – corporate tax details
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
Federal Finance Court
Treaty between India and UK – Indian decision on ascertainment of "business connection"/PE and attribution of profits
UK-Switzerland income tax treaty: memoranda of understanding
Merger of UK companies with Italian PEs: tax consequences
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law
US
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
Treaty between Australia and United Kingdom – ATO interprets by reference to LOB provision in treaty between Australia and United States
Business tax reform: capital allowance changes
ECJ: Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital – details
OECD released discussion draft on transactional profit methods
Treaty between Japan and United Kingdom (1969) – Japan's NTA uncovers treaty-shopping scheme
ECJ: German transitional rules for taxation of capital gains incompatible with EC free movement of capital
Protocol to treaty between UK and Switzerland ratified
Communication published on application of anti-abuse measures in area of direct taxation – within the EU and in relation to third countries
Consultation on principles-based approach to financial products avoidance
ECJ:Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital
IRS releases text of US-UK mutual agreement on definition of "first notification" under US-UK income tax treaty
Treaty between Russia and United Kingdom – Russian Ministry of Finance clarifies application of treaty provisions re deduction of expenses incurred for purposes of PE located in Russia
Protocol between United Kingdom and New Zealand signed – details
Treaty between United Kingdom and Saudi Arabia signed
ECJ: Advocate General finds Swedish legislation limiting the exemption of third-country dividends justifiable restriction on EC free movement of capital – details
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