Ashley Greenbank (Macfarlanes) reviews the proposals on company distributions, which would amend the transactions in securities rules and introduce a new targeted anti-avoidance rule.
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.
The changes to the taxation of dividends proposed in the Budget seem to be worthy of rather more attention than they have received, writes Peter Vaines.