There has been a short quiet phase in the ongoing international tax reform programme in the UK as we wait for the next stage. Changes were made to the new investment company election in the Finance Bill. The Upper Tribunal has found for the taxpayer in the First Nationwide case. Adoption of an EU CCCTB is unlikely to simplify the overall taxation of US companies with operations in Europe. Permission to appeal to the Supreme Court has been refused in Test Claimants in the ACT Group Litigation (Classes 4 and 2). The German government is challenging the European Commission’s decision on German rules on loss carry-forwards for ailing companies.
