EU direct tax newsalerts

The EU direct tax newsalerts are issued on an ad hoc basis to provide our clients and other interested parties with the very latest news on the most important European Court of Justice (ECJ) decisions and national developments in Europe in the field of direct taxation. Each newsalert contains a short background to a particular case and an analysis prepared by members of PricewaterhouseCoopers' EU direct tax group (EUDTG).

Below you will find the EUDTG newsalerts published in 2008 and 2009. For earlier newsalerts, please visit the archive.

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Newsalert: 30 October 2009. NA 2009: 026  (420kb)
European Commission classifies Hungarian intra-group interest regime as existing aid.

Newsalert: 29 October 2009. NA 2009: 025  (424kb)
European Commission: Spanish goodwill amortisation scheme constitutes State aid within the meaning of Art. 87(1) EC

Newsalert: 26 October 2009. NA 2009: 024  (447kb)
European Commission recommends simplified procedures for claiming back crossborder withholding tax relief.

Newsalert: 26 October 2009. NA 2009: 023  (422kb)
The First-Tier Tribunal found that the consortium (i.e. joint venture) loss relief rules in the UK are an unjustifiable breach of the freedom of establishment, in that they apply to prevent loss relief in cases where the link company is not a UK resident, but resident elsewhere in the EU.

Newsalert: 12 October 2009. NA 2009: 022  (423kb)
The European Commission has announced that it has decided to refer the UK to the European Court of Justice for improper implementation of the ECJ decision in the Marks & Spencer case concerning cross-border loss relief.

Newsalert: 9 October 2009. NA 2009: 021  (421kb)
European Commission refers Portugal to the ECJ for its restrictive exit tax provisions for companies

Newsalert: 9 October 2009. NA 2009: 020  (708kb)
On 8 October 2009, the European Commission decided to refer Spain to the European Court of Justice in relation to their tax provisions on exit tax for companies.

Newsalert: 2 October 2009. NA 2009: 019  (712kb)
The European Court of Justice on 1/10/09 in case C-569/07 ruled that the 1.5% Stamp Duty Reserve Tax (SDRT) charge levied by the UK upon the issuance of new securities into a clearance service is contrary to EU law.

Newsalert: 1 October 2009. NA 2009: 018  (722kb)
Poland to end discriminatory treatment of non-resident EU / EEA pension and investment funds investing in Poland before end of 2009

Newsalert: 1 October 2009. NA 2009: 017  (718kb)
Norwegian Government amends the application of the tax exemption method in EU / EEA situations

Newsalert: 25 September 2009. NA 2009: 016  (682kb)
Sweden proposes to introduce limited “group deduction” for foreign tax losses

Newsalert: 24 July 2009. NA 2009: 015  (720kb)
ECJ judgment in Damseaux (case C-128/08)

Newsalert: 10 July 2009. NA 2009: 014  (709kb)
ECJ: Spanish capital tax rules are incompatible with EC Law (Commission v. Spain; C-397/07)

Newsalert: 8 july 2009. NA 2009: 013  (707kb)
European Commission: ‘groepsrentebox’ is not state aid

Newsalert: 29 June 2009. NA 2009: 012  (708kb)
European Commission formally requests Spain to change its tax provisions concerning the taxation of capital gains arising from an exchange of shares

Newsalert: 25 June 2009. NA 2009: 011  (709kb)
European Commission requests Denmark and Finland to end discriminatory treatment of foreign pension funds

Newsalert: 16 June 2009. NA 2009: 010  (728kb)
The European Court of Justice delivered its final judgement in the Aberdeen (C-303/07) case (C-303/07)

Newsalert: 16 June 2009. NA 2009: 009  (711kb)
Expected extension of Cobelfret case law (C-138/07) to internal situations, and potentially to third countries

Newsalert: 15 June 2009. NA 2009: 008  (707kb)
Dutch dividend withholding tax on EEA distributions contravenes European law

Newsalert: 22 May 2009. NA 2009: 007  (712kb)
UK Court of Appeal allows HMRC’s appeal in the Vodafone 2 case for the ECJ’s Cadbury judgment to be "read down" into the UK Controlled Foreign Company (CFC) legislation

Newsalert: 6 May 2009. NA 2009: 006 (708kb)
Spanish Government announces amendment to the Non-residents Income Tax Act (Pension Funds and rules for determining the taxable base)

Newsalert: 20 March 2009. NA 2009: 005 (710kb)
Court of First Instance: Italian regime for investment vehicles specialised in small- and mid-caps constitutes State aid

Newsalert: 16 March 2009. NA 2009: 004 (685kb)
Swedish group relief system is not in line with the freedom of establishment, says Swedish Supreme Administrative Court

Newsalert: 25 February 2009. NA 2009: 003 (683kb)
Belgian Notional Interest Deduction: European Commission requests Belgium to extend the regime

Newsalert: 17 February 2009. NA 2009: 002 (682kb)
French Supreme Court decides on the compatibility of withholding tax due by EU pension funds on French dividends

Newsalert: 29 January 2009. NA 2009: 001 (709kb)
Dutch Tax Authorities to reimburse Dutch dividend withholding tax to EUbased pension funds

Newsalert: 24 December 2008. NA 2008: 019 (708kb)
ECJ in Truck Center: Belgian withholding tax on interest payments to non-resident companies compatible with freedom of establishment

Newsalert: 19 December 2008. NA 2008: 018 (684kb)
ECJ judgment in Cartesio case (C-210/06)

Newsalert: 28 November 2008. NA 2008: 017 (683kb)
ECJ Decision in the Papillon case (C-418/07): French tax group regime in breach of the freedom of establishment

Newsalert: 27 June 2008. NA 2008: 016 (687kb)
ECJ decision in the Burda case (C-284/06)

Newsalert: 3 June 2008. NA 2008: 015 (700kb)
Advocate General Maduro’s Opinion in the Cartesio case (C-210/06)

Newsalert: 16 May 2008. NA 2008: 014 (687kb)
ECJ jugdment in the Lidl Belgium case (C-414/06)

Newsalert: 15 May 2008. NA 2008: 013 (712kb)
Commission issues a working document on anti-abuse rules for the CCCTB

Newsalert: 29 February 2008. NA 2008: 012 (685kb)
Judgment in the Deutsche Shell case (C-293/06): Non-deductibility of currency losses from foreign exempt permanent establishments restricts the freedom of establishment.

Newsalert: 15 February 2008. NA 2008: 011 (686kb)
AG opinion in the Lidl Belgium case (C-414/06)

Newsalert: 14 February 2008. NA 2008: 010 (682kb)
Dutch Supreme Court: costs relating to lower tier subsidiaries in third countries held through EU intermediate subsidiaries not deductible (Case 43083)

Newsalert: 5 February 2008. NA 2008: 009 (695kb)
Italy referred to ECJ over discriminatory taxation of outbound dividends (Case C-540/07, Commission v Italy)

Newsalert: 31 January 2008. NA 2008: 008 (699kb)
A-G opinion on the compatibility of the French Tax Code with the Parent-Subsidiary:Banque Fédérative du Crédit Mutuel case

Newsalert: 1 February 2008. NA 2008: 007 (685kb)
AG opinion in the Burda case (C-284/06)

Newsalert: 1 February 2008. NA 2008: 006 (685kb)
The Commission's announcements on (i) the start of infringement proceedings against Germany and Estonia for their discriminatory taxation of dividend and interest payments to foreign EU pension funds and (ii) the Reasoned Opinions send to Germany regarding its discriminatory rules applied to non-resident taxpayers (mainly artists, sportsmen and journalists) and its discriminatory depreciation rules applied to buildings situated abroad.

Newsalert: 30 January 2008. NA 2008: 005 (682kb)
ECJ decision in the Jäger case (C-256/06)

Newsalert: 25 January 2008. NA 2008: 004 (712kb)
On 10 and 11 December 2007, a joint meeting of the European Commission with businesses and academics took place in Brussels, with the EU Member States attending as observers. The purpose of the meeting was to give participants an overall update of the CCCTB Working Group’s work to date, focusing especially on a number of discussion documents on the possible outline of a CCCTB. We summarise below the main points coming out of these discussion documents.

Newsalert: 23 January 2008. NA 2008: 003 (702kb)
ECJ judgment in case C- 105/07 : Recharacterisation of interest as dividend

Newsalert: 10 January 2008. NA 2008: 002 (681kb)
Finnish Supreme Administrative Court decisions: Even in case of ‘final losses’ no cross-border group contribution possible

Newsalert: 10 January 2008. NA 2008: 001 (682kb)
ECJ judgment in case C-101/05 ("A-case"): ECJ clarifies the concept of free movement of capital to and from third countries