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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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Pre-Budget Report for 2007-08

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Treaty between Poland and United Kingdom ratified

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ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment

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Dutch clarification on credit for withholding tax and application of redistribution

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Tax treaty between Peru and the United Kingdom - negotiations

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Implementation of EC Merger Directive

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UK–US treaty agreement on dual consolidated losses

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Treaty between Japan and UK to enter into force

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Draft guidance on application of Indofood case (interpretation of "beneficial ownership" under Indonesia-Netherlands tax treaty)

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ECJ: UK CFC rules in breach of freedom of establishment unless application limited to wholly artificial arrangements – details

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New tax treaty between Poland and UK signed – details

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European Commission requests Belgium to terminate discriminatory taxation of inbound dividends

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European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive

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European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid

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Finance Act 2006 enacted

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European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures

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European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends

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Treaty programme priorities

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Extension of tax avoidance scheme disclosure rules

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Australian treatment of shipping and aircraft leasing profits of UK and US enterprises

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Avoidance of tax by factoring of business income

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Indian ruling on taxability of payments for information under India-UK tax treaty

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Treaty between United Kingdom and Japan signed

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Protocol and MoU to treaty between Switzerland and UK initialled

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UK

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UKCourt of Appeal decides on residence status of foreign company re inter alia Netherlands-UK treaty

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US Court

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The Chilean Tax Authorities has issued Circular Letter 63 of 24 November 2005. The Circular provides that, after consultation with the UK tax authorities, the term "United Kingdom", as used in Art. 3 Para. 1(c) of the tax treaty between Chile and the United Kingdom, does not include the "Overseas Territories" and the "Crown Dependencies".

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Pre-Budget Report for 2006-07

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Court of Appeals of Paris decides on concept of beneficial owner under France-UK tax treaty

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