United Kingdom Tax News

International tax conference on CCCTB held in Berlin

18 June 2007

Italian tax authorities issue ruling re treatment of Italian PE of UK partnership, income paid by UK partnership to Italian partners

18 June 2007

Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

18 June 2007

Treaty between France and UK – Court of Appeals of Paris rules on agency permanent establishment

18 June 2007

Revised Commentary on Article 7 of OECD Model released

28 May 2007

Extension of tax avoidance scheme disclosure rules

28 May 2007

Treaty between the United Kingdom and Switzerland – UK Court of Appeal decides on non-discrimination relief

28 April 2007

ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details

28 April 2007

Capital gains treatment of capital contributions

28 April 2007

Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement

24 March 2007

Final Report on Improving the Resolution of Tax Treaty Disputes

24 March 2007

ECJ: hearing in case regarding Dutch withholding tax on outbound dividends

24 March 2007

French Supreme Administrative Court

24 March 2007

Decree on Dutch clarification on credit for withholding tax and application of redistribution facility for dividends received from UK replaced

24 February 2007

EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies

24 February 2007

EU Commission requests Italy to implement the Interest and Royalties Directive correctly

24 February 2007

Report on Attribution of Profits to PEs released

24 February 2007

New income tax treaty between United Kingdom and Poland enters into force

24 February 2007

EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends

24 February 2007

Pre-Budget Report for 2007-08

15 January 2007

ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details

15 January 2007

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

15 January 2007

Treaty between Poland and United Kingdom ratified

15 January 2007

Dutch clarification on credit for withholding tax and application of redistribution

17 December 2006

Tax treaty between Peru and the United Kingdom - negotiations

17 December 2006

Implementation of EC Merger Directive

17 December 2006

UK–US treaty agreement on dual consolidated losses

12 November 2006

Treaty between Japan and UK to enter into force

12 November 2006

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

12 November 2006

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

14 October 2006