The Supreme Tax Court in Germany has clarified that not only did the country’s old thin capitalisation rules not comply with the freedom of establishment provision of the European Community (EC) treaty, but they also infringed the non-discrimination clause of treaties relating to companies resident in non-EC countries.
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Wopke Hoekstra also swore the EU would ‘hit back harder’ if faced with a trade war; in other news, a UK watchdog has launched an investigation into an audit completed by MHA
A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland