United Kingdom Tax News
Pre-Budget Report for 2008-09
ECJ: hearing in case regarding transitional rules in respect of abolished German imputation system
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
Accession Convention to Arbitration Convention for 10 new Member States ratified by UK
Business tax reform consultation
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
Tax treaty developments
ECJ: Finnish group contribution regime compatible with EC Law – details
Finance Act 2007
Protocol to treaty between UK and Switzerland signed
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
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published
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: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
Non-discrimination and group income elections
Taxation of foreign profits of companies
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
Italian tax authorities issue ruling re treatment of Italian PE of UK partnership, income paid by UK partnership to Italian partners
Treaty between France and UK – Court of Appeals of Paris rules on agency permanent establishment
International tax conference on CCCTB held in Berlin
Capital gains degrouping charge
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Revised Commentary on Article 7 of OECD Model released
Extension of tax avoidance scheme disclosure rules
Capital gains treatment of capital contributions
Treaty between the United Kingdom and Switzerland – UK Court of Appeal decides on non-discrimination relief
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