Orbitax Tax News & Alerts
United Kingdom's Tax news & updates from Orbitax and partners
United Kingdom Tax News
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
Finance Act 2007
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details
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
Non-discrimination and group income elections
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
Taxation of foreign profits of companies
Capital gains degrouping charge
International tax conference on CCCTB held in Berlin
Italian tax authorities issue ruling re treatment of Italian PE of UK partnership, income paid by UK partnership to Italian partners
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Treaty between France and UK – Court of Appeals of Paris rules on agency permanent establishment
Revised Commentary on Article 7 of OECD Model released
Extension of tax avoidance scheme disclosure rules
Treaty between the United Kingdom and Switzerland – UK Court of Appeal decides on non-discrimination relief
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
Capital gains treatment of capital contributions
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
French Supreme Administrative Court
Decree on Dutch clarification on credit for withholding tax and application of redistribution facility for dividends received from UK replaced
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
New income tax treaty between United Kingdom and Poland enters into force
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
Pre-Budget Report for 2007-08
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