The CJEU embraces a ‘per-element approach’ and considers the limitation of certain tax advantages to purely national situations of tax-integrated groups to be a violation of the freedom of establishment.
Richard Insole and Judith Lesar (Deloitte) review the Mapfre case, which clarifies the term ‘insurance’ for VAT purposes but raises questions about the treatment of certain warranty contracts.
Steve Powell and Karen Killington (KPMG) consider the questions referred to the CJEU in the National Exhibition Centre Ltd case concerning the VAT exemption for card handling services.
Chris Morgan (KPMG) provides a review of recent international tax developments that matter.
In this month’s briefing, Lee Squires and Fiona Bantock (Hogan Lovells) examine four recent VAT cases: Larentia and Marenave, Southern Cross, Wojskowa and Property Development Company NV
A recent CJEU decision on French social contributions on non-residents triggers a run for refunds.
HMRC’s guidance on Skandia is a useful starting point, but still leaves considerable uncertainty on one of the highest profile VAT developments for the financial services industry in recent years, write Gary Campbell and Daniel Johnson (Deloitte).
Christopher Morgan (KPMG) provides an update of recent developments, including: the OECD’s BEPS project; the CJEU decision in the EC’s challenge to UK cross-border relief; the Prudential Assurance case; the EC investigation into Belgium’s excess profit rulings; and news from Ireland and the US.
The CJEU judgment in European Commission v UK has rejected a challenge to the UK group relief legislation, following on from the Marks and Spencer litigation. Rupert Shiers (Hogan Lovells) reviews the decision and asks where this leaves us.