Orbitax Tax News & Alerts
Ireland's Tax news & updates from Orbitax and partners
Ireland Tax News
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
International tax conference on CCCTB held in Berlin
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Revised Commentary on Article 7 of OECD Model released
Finance Act for 2007 enacted
Ireland implements European Company Statute
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
Budget for 2007 - highlights
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
Report on Attribution of Profits to PEs released
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
German Federal Tax Court holds CFC rules not applicable in cases of administratively limited tax relief in order to comply with low taxation threshold
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
Status of Irish common contractual funds under the Ireland-US tax treaty
Treaty between Ireland and Italy – Irish CGT not covered
Finance Bill 2006
Additional protocol between Ireland and Portugal signed
On 7 December 2005, the Budget for 2006 was presented by the Minister of Finance. Unless otherwise stated, the proposals are expected to take effect from 1 January 2006. The proposals for companies include: the introduction of measures to restrict relief for interest paid in the context of certain related company transactions with effect from 7 December 2005.
Unify Your Processes
Simplify Compliance
Empower Your Team