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United Kingdom Tax News

Federal Finance Court

16 March 2008
US

16 March 2008
Merger of UK companies with Italian PEs: tax consequences

16 March 2008
UK-Switzerland income tax treaty: memoranda of understanding

16 March 2008
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law

16 March 2008
European Commission takes steps against Belgium for failure to adopt implementing measures of Merger Directive

16 March 2008
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details

16 March 2008
European Commission takes steps against Germany, Estonia and Czech Republic regarding taxation of outbound dividends

16 March 2008
Treaty between India and UK – Indian decision on ascertainment of "business connection"/PE and attribution of profits

16 March 2008
ECJ: Advocate General finds the 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive

8 February 2008
Treaty between Japan and United Kingdom (1969) – Japan's NTA uncovers treaty-shopping scheme

8 February 2008
Treaty between Australia and United Kingdom – ATO interprets by reference to LOB provision in treaty between Australia and United States

8 February 2008
Business tax reform: capital allowance changes

8 February 2008
ECJ: Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital – details

8 February 2008
European Commission issues communication regarding accession of Bulgaria and Romania to Arbitration Convention

8 February 2008
OECD released discussion draft on transactional profit methods

8 February 2008
Communication published on application of anti-abuse measures in area of direct taxation – within the EU and in relation to third countries

16 January 2008
Consultation on principles-based approach to financial products avoidance

16 January 2008
ECJ: German transitional rules for taxation of capital gains incompatible with EC free movement of capital

16 January 2008
ECJ:Swedish legislation limiting exemption of third-country dividends justifiable restriction on EC free movement of capital

16 January 2008
Protocol to treaty between UK and Switzerland ratified

16 January 2008
IRS releases text of US-UK mutual agreement on definition of "first notification" under US-UK income tax treaty

3 December 2007
Treaty between Russia and United Kingdom – Russian Ministry of Finance clarifies application of treaty provisions re deduction of expenses incurred for purposes of PE located in Russia

3 December 2007
Protocol between United Kingdom and New Zealand signed – details

3 December 2007
Treaty between United Kingdom and Saudi Arabia signed

3 December 2007
ECJ: Advocate General finds Swedish legislation limiting the exemption of third-country dividends justifiable restriction on EC free movement of capital – details

4 November 2007
ECJ: hearing in case regarding transitional rules in respect of abolished German imputation system

4 November 2007
Pre-Budget Report for 2008-09

4 November 2007
Business tax reform consultation

2 September 2007
Tax treaty developments

2 September 2007
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