United Kingdom Tax News

Treaty between Australia and UK – negotiations

24 December 2008

Treaty between India and UK – Indian ruling on whether payments for lease of satellite transponder qualify as royalty

24 December 2008

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

4 November 2008

Treaty between UK and Netherlands – details

4 November 2008

Preliminary ruling requested from ECJ regarding Belgian anti-abuse provision concerning exceptional and gratuitous advantages

4 November 2008

Treaty between UK and Slovenia enters into force

4 November 2008

Preliminary ruling requested from ECJ on interpretation of EC Parent-Subsidiary Directive with respect to Italian tax on dividend adjustment (General Beverage)

4 November 2008

Double taxation relief – surrender of relievable tax within a group: regulations amended

4 November 2008

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.

4 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

4 November 2008

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

7 October 2008

2001 treaty between United States and United Kingdom – IRS issues interpretation of Art. 18 (Pension Schemes)

7 October 2008

Protocol to treaty between New Zealand and United Kingdom enters into force

7 October 2008

OECD released 2008 Model Tax Convention

7 October 2008

Protocol to treaty between UK and Switzerland – signed and details

7 October 2008

Protocol to treaty between UK and New Zealand ratified

30 August 2008

Netherlands

30 August 2008

Treaty negotiation priorities announced

30 August 2008

Treaty between UK and Saudi Arabia ratified

30 August 2008

Discussion draft on New Art. 7 of OECD Model – details

30 August 2008

Treaty between UK and Slovenia ratified

30 August 2008

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

11 August 2008

OECD Council approves 2008 Model Tax Convention

11 August 2008

Treaty between France and United Kingdom – details

11 August 2008

Financial Court of Düsseldorf rules on transfer pricing adjustments

11 August 2008

Finance Act 2008 receives Royal Assent

11 August 2008

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

11 August 2008

2008 treaty between France and United Kingdom signed

27 July 2008

Implementation of Mergers Directive

27 July 2008

Treaty between United Kingdom and Slovenia – details

27 July 2008