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International review

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Speed Read: HMRC is consulting on a treaty relief 'passport' scheme for withholding tax. The First Tier Tribunal published an interesting decision on the old group relief rules. The Advocate General rejected the EC's claim in the Commission v Portugal case on withholding tax. In the Gielen case the ECJ decided a discriminatory regime cannot be made non-discriminatory by offering an alternative. The US IRS has published more information on its proposals for reporting uncertain tax positions. Changes have been made to the US Tax Statute of Limitations rule. The French courts have confirmed a French commissionaire acting as an undisclosed agent does not constitute a PE of its UK principal.

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