Orbitax

United Kingdom Tax News

Accession Convention to Arbitration Convention for 10 new Member States ratified by UK

2 September 2007

OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments

2 September 2007

Compatibility of exclusion of indirect ownership through companies in other EU Member States for French tax consolidation purposes with freedom of establishment referred to ECJ

2 September 2007

Protocol to treaty between UK and Switzerland signed

29 July 2007

EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends

29 July 2007

EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends

29 July 2007

ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details

29 July 2007

ECJ: Finnish group contribution regime compatible with EC Law – details

29 July 2007

Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published

29 July 2007

Finance Act 2007

29 July 2007

ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details

2 July 2007

Non-discrimination and group income elections

2 July 2007

ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details

2 July 2007

ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details

2 July 2007

ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law

2 July 2007

ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details

2 July 2007

Taxation of foreign profits of companies

2 July 2007

Capital gains degrouping charge

18 June 2007

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

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

28 April 2007

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

28 April 2007

Capital gains treatment of capital contributions

28 April 2007

Final Report on Improving the Resolution of Tax Treaty Disputes

24 March 2007

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

24 March 2007

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

24 March 2007

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