Orbitax Tax News & Alerts
United Kingdom's Tax news & updates from Orbitax and partners
United Kingdom Tax News
ECJ: Cobelfret extended to domestic situations and potentially to dividends received from third countries
ECJ: Netherlands' non-exemption of dividends paid to certain EEA countries from withholding tax found incompatible with EEA Agreement
New treaty between Israel and United Kingdom – principle points agreed, but not yet signed
ECJ finds Finnish dividend withholding tax regime incompatible with EC freedom of establishment
Protocol to treaty between Isle of Man and UK enters into force
European Commission refers Germany to ECJ over taxation of outbound dividends
Treaty between India and UK – Indian decision on whether payments for software constitutes royalty or business income
UK ratifies tax treaty with France
Protocol between UK and Switzerland enters into force
Pre-Budget Report for 2009-10 presented to Parliament
Treaty between Australia and UK – negotiations
Treaty between India and UK – Indian ruling on whether payments for lease of satellite transponder qualify as royalty
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
Treaty between UK and Netherlands – details
Preliminary ruling requested from ECJ regarding Belgian anti-abuse provision concerning exceptional and gratuitous advantages
Treaty between UK and Slovenia enters into force
Preliminary ruling requested from ECJ on interpretation of EC Parent-Subsidiary Directive with respect to Italian tax on dividend adjustment (General Beverage)
Double taxation relief – surrender of relievable tax within a group: regulations amended
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 Belgian withholding tax on interest paid to companies resident in other Member States compatible with EC freedom of establishment – details
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
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
OECD released 2008 Model Tax Convention
Protocol to treaty between UK and Switzerland – signed and details
Protocol to treaty between UK and New Zealand ratified
Netherlands
Treaty negotiation priorities announced
Treaty between UK and Saudi Arabia ratified
Discussion draft on New Art. 7 of OECD Model – details
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