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Marks and Spencer v David Halsey (Her Majesty’s Inspector of Taxes),

Articles 43 EC and 48 EC; Corporation tax; Groups of companies; Tax relief; Profits of parent companies; Deduction of losses incurred by a resident subsidiary; Allowed; Deduction of losses incurred in another Member State by a non-resident subsidiary; UK regulations could prevent parent companies from using foreign subsidiaries' losses to reduce their home tax bill;

December 13 2005

Marks & Spencer plc v David Halsey (HM Inspector of Taxes)

Articles 43 EC and 48 EC – Corporation tax – Groups of companies – Tax relief – Profits of parent companies – Deduction of losses incurred by a resident subsidiary – Allowed – Deduction of losses incurred in another member state by a non-resident subsidiary – Not included.

December 13 2005

SEVIC Systems Aktiengesellschaft v Amtsgericht Neuwied

Freedom of establishment – Articles 43 EC and 48 EC – Cross-border mergers – Refusal of registration in the national commercial register – Compatibility.

December 13 2005

Jyske Finans A/S v Skatteministeriet

Sixth VAT Directive – Article 13B(c) – Exemptions – Exemption of supplies of goods excluded from the right to deduct – Resale of motor cars purchased second-hand by a leasing company – Article 26a – Special arrangements for sales of second-hand goods.

December 08 2005

Commissioners of Customs & Excise Attorney General v Federation of Technological Industries

Sixth VAT Directive – Articles 21(3) and 22(8) – Joint and several liability for payment of VAT – Principles of proportionality and legal certainty – Missing trader intra-Community fraud – Carousel fraud.

December 07 2005

Why Indian transfer pricing rules are lacking

By Markus Brem, GlobalTransferPricing Business Solutions, Munich

December 01 2005

NZ and Australia update tax agreement

New Zealand and Australia have revised their double tax agreement, including updating an agreement on exchange of information and extending their cooperation on tax collection, which is expected to affect wine producers in particular. Peter Dunne, New Zealand's minister for revenue, said a decision to negotiate a completely new double tax agreement was still under review in both countries.

December 01 2005

PricewaterhouseCoopers

December 01 2005

Paul, Hastings announces new US tax partner

Alexander Lee has been made a tax partner of Paul, Hastings, Janofsky & Walker in its Orange County, California office. His practice concentrates on M&A, dispositions, and recapitalizations of corporations, particularly complex international corporate transactions.

December 01 2005

Chancellor grabs more tax from North Sea

Changes to oil tax regime The tax hike for North Sea oil and gas producers, announced in the UK's 2005 pre-Budget report, has been described as "almost beyond comprehension" by the UK Offshore Operators' Association.

December 01 2005

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