Orbitax Tax News & Alerts
United Kingdom's Tax news & updates from Orbitax and partners
United Kingdom Tax News
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details
Business tax reform: capital allowance changes
European Commission issues communication regarding accession of Bulgaria and Romania to Arbitration Convention
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
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
Treaty between Japan and United Kingdom (1969) – Japan's NTA uncovers treaty-shopping scheme
Communication published on application of anti-abuse measures in area of direct taxation – within the EU and in relation to third countries
ECJ: German transitional rules for taxation of capital gains incompatible with EC free movement of capital
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
Protocol to treaty between UK and Switzerland ratified
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
Treaty between United Kingdom and Saudi Arabia signed
Protocol between United Kingdom and New Zealand signed – details
ECJ: Advocate General finds Swedish legislation limiting the exemption of third-country dividends justifiable restriction on EC free movement of capital – details
ECJ: hearing in case regarding transitional rules in respect of abolished German imputation system
Pre-Budget Report for 2008-09
Business tax reform consultation
Accession Convention to Arbitration Convention for 10 new Member States ratified by UK
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
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
Tax treaty developments
Protocol to treaty between UK and Switzerland signed
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
ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details
ECJ: Finnish group contribution regime compatible with EC Law – details
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