The Supreme Court of the Netherlands has delivered a judgment which allows a Dutch taxpayer to deduct losses incurred on a related party loan, creating an exception to the shareholder loan doctrine set out by the court in November 2011.
Venture Capital Trusts (VTC) and Investment Trust Companies (ITC) risk losing out on reclaiming VAT mistakenly paid to HM Revenue & Customs (HMRC) if they do not act now.
The Finnish government is asking India to enter a mutual agreement procedure (MAP) under the tax treaty between the two countries in an attempt to negotiate a settlement over Nokia's controversial INR 2,000-crore ($368.8 million) tax bill.
Brazilian taxpayers are left with several options following the Supreme Federal Court’s (STF) judgment on the constitutionality of the controlled foreign company (CFC) rules last month, advisers say.
The European Commission is renewing its inquiry into tax benefits provided to Electricité de France (EDF) by the French government despite the European Court of Justice (ECJ) finding in the taxpayer’s favour last June.
The European Court of Justice’s (ECJ) decision that Spanish companies transferring assets to another EU member state can defer exit tax payment was unsurprising given the court’s rulings in National Grid Indus and Portugal v Commission. But advisers say the ECJ is leaving important questions unanswered.
