Alan Dolton editor of Tolley's Tax Cases reviews some of the leading direct tax decisions reached during 2006
The ECJ delivered a lengthy and important judgment in Test Claimants in the FII Group Litigation v CIR holding that 'where a Member State has a system for preventing or mitigating the imposition of a series of charges to tax or economic double taxation as regards dividends paid to residents by resident companies it must treat dividends paid to residents by non-resident companies in the same way' (ECJ Case C-446/04; 12 December 2006 unreported). The ECJ also delivered an important judgment in Cadbury Schweppes plc v CIR holding that measures such as the UK's CFC legislation could only be applied to 'wholly artificial arrangements' and could not be applied where a CFC...
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Alan Dolton editor of Tolley's Tax Cases reviews some of the leading direct tax decisions reached during 2006
The ECJ delivered a lengthy and important judgment in Test Claimants in the FII Group Litigation v CIR holding that 'where a Member State has a system for preventing or mitigating the imposition of a series of charges to tax or economic double taxation as regards dividends paid to residents by resident companies it must treat dividends paid to residents by non-resident companies in the same way' (ECJ Case C-446/04; 12 December 2006 unreported). The ECJ also delivered an important judgment in Cadbury Schweppes plc v CIR holding that measures such as the UK's CFC legislation could only be applied to 'wholly artificial arrangements' and could not be applied where a CFC...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
