- Orbitax

United Kingdom Tax News

European Commission requests Belgium to terminate discriminatory taxation of inbound dividends

13 August 2006

New tax treaty between Poland and UK signed – details

13 August 2006

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

13 August 2006

Finance Act 2006 enacted

13 August 2006

Treaty programme priorities

13 August 2006

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

13 August 2006

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

13 August 2006

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

13 August 2006

Extension of tax avoidance scheme disclosure rules

11 July 2006

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

11 July 2006

Avoidance of tax by factoring of business income

11 July 2006

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

14 June 2006

Treaty between United Kingdom and Japan signed

16 March 2006

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

16 March 2006

UK

16 March 2006

Protocol and MoU to treaty between Switzerland and UK initialled

16 March 2006

US Court

19 February 2006

Pre-Budget Report for 2006-07

1 January 2006

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".

1 January 2006

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

21 September 2005

The Finance (No. 3) Bill was published on 26 May 2005. The Bill reintroduces into Parliament the provisions of the original Finance Bill 2005 that were dropped when the Finance Act 2005 was enacted. Important details include:

21 September 2005

Following a final round of negotiations on 26 May 2005, the United Kingdom and Japan reached an agreement in principle on a new tax treaty. Once in force, the new treaty will replace the United Kingdom-Japan income tax treaty of 10 February 1969 (as amended by the 1980 protocol). Further details of the new treaty are not yet available.

3 August 2005

The Internal Revenue Service (IRS) has released the text of a private letter ruling (PLR) on 3 June 2005 holding that stock of a US corporation owned by a UK company through foreign entities that elect to be treated as disregarded entities under the US check-the-box regulations can qualify for the zero dividend withholding rate under

3 August 2005

The Inland Revenue announced on 12 July 2005 details of the United Kingdom's tax treaty negotiating priorities for the year to 31 March 2006. These include:

3 August 2005

Entry into force on 21 December 2004, effective as from 1 January 2005 in Chile and as from 1 April 2005 (in respect of corporation tax, for any financial year beginning on or after 1st April) or 6 April 2005 (in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6th April 2005) in the United Kingdom.

19 January 2005

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