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  • Test Claimants in Class IV of the ACT Group Litigation (Pirelli, Essilor and Sony), Test Claimants in Class IV of the ACT Group Litigation (BMW) v Commissioners of Inland Revenue
    Interpretation of Articles 43 and 56 EC – National legislation on corporation tax – Retention at source (‘advance corporation tax’) from the profits distributed by a subsidiary to a parent company – Tax credit designed to take account of a retention made upstream.
    February 23 2006
  • Dollond & Aitchison Ltd v Commissioners of Customs & Excise
    Community Customs Code – Customs value – Customs import duties – Delivery of goods by a company established in Jersey and supplies of services effected in the United Kingdom.
    February 23 2006
  • Finanzamt Offenbach am Main-Land v Keller Holding GmbH
    Freedom of establishment – Corporation tax – Right of a parent company to deduct costs relating to its shareholdings – Non-deductible financing costs having an economic link with dividends exempt from tax – Dividends distributed by an indirect subsidiary established in a member state other than that in which the parent company has its seat.
    February 23 2006
  • Isle of Man scraps corporation tax
    The Isle of Man, the UK Crown dependency in the Irish Sea, is on course to introduce a 0% corporation tax rate as standard from April 5, in line with taxation plans it announced in 2000, according to the budget statement of Allan Bell, the island's finance minister.
    February 22 2006
  • GAAR on the way to South Africa
    The South African government announced plans for an advanced ruling system and legislation on a general anti-avoidance rule in its budget on February 15
    February 22 2006
  • Italy signs up to OECD tax convention
    Italy will become the 12th country to sign up to the joint Council of Europe/OECD Convention on Mutual Assistance in Tax Matters on May 1
    February 22 2006
  • US suggest leniency to tax shelter promoters
    According to the International Herald Tribune of February 14, the US tax authorities are offering law firms, accounting firms, banks and investment firms that put together aggressive tax schemes a chance to "come forward, pay penalties and turn over information" and avoid criminal prosecution
    February 22 2006
  • WTO sides with EU in FSC/ETI dispute
    The WTO's Appellate Body has upheld the EU's complaint that the US is continuing to maintain foreign sales corporation and extra-territorial income subsidies that the WTO has previously declared illegal
    February 22 2006
  • OECD to meet business sector on attribution of profits
    The OECD's Centre for Tax Policy and Administration (CTPA) is holding a consultation with business on Part IV (Insurance) of the discussion draft on the attribution of profits to permanent establishments. The meeting will take place on Friday, March 31 at the OECD offices in Paris
    February 22 2006
  • OECD to discuss dispute settlement with business
    The OECD Centre for Tax Policy and Administration will hold, in cooperation with the Business and Industry Advisory Committee, a consultation between business and government on recent OECD initiatives to improve dispute settlement procedures under tax treaties on March 13 in Tokyo
    February 22 2006
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