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Orbitax Tax News & Alerts

United Kingdom's Tax news & updates from Orbitax and partners

United Kingdom Tax News

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Treaty between UK and Slovenia ratified

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Exchange of information agreement between United Kingdom and Bermuda – ratified and details

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OECD Council approves 2008 Model Tax Convention

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Treaty between France and United Kingdom – details

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Financial Court of Düsseldorf rules on transfer pricing adjustments

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Finance Act 2008 receives Royal Assent

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Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax

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2008 treaty between France and United Kingdom signed

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Implementation of Mergers Directive

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Treaty between United Kingdom and Slovenia – details

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Comments on draft contents of 2008 update to Model Tax Convention published

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European Commission closes infringement procedure against Luxembourg concerning taxation of dividends

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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

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European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends

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ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment

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ECJ: Decision by reasoned order in UK CFC and foreign dividend test case

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ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital

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Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)

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ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive

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European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax

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Corporation tax – interest rates

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Budget for 2008-09 – corporate tax details

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Treaty between India and UK – Indian decision on ascertainment of "business connection"/PE and attribution of profits

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Federal Finance Court

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US

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Merger of UK companies with Italian PEs: tax consequences

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ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law

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UK-Switzerland income tax treaty: memoranda of understanding

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ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details

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European Commission takes steps against Germany, Estonia and Czech Republic regarding taxation of outbound dividends

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