Chris Morgan UK Head of KPMG Europe's International Corporate Tax Group and Jonathan Bridges Senior Manager discuss the ECJ Columbus Containers case
On 6 December 2007 the European Court of Justice (ECJ) delivered its decision in the Columbus Containers DVBA & Co (Case C-298/05) case. It held that although Germany usually exempts foreign profits from German tax it was not contrary to the EC Treaty for this exemption to be overridden where the foreign profits had been subject to foreign tax of less than 30%.
The case has been seen by some commentators as partly restricting or at least going back on the decision in Cadbury Schweppes (Case C-196/04) which held that the UK's controlled foreign company (CFC) rules were unlawful unless only applied...
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Chris Morgan UK Head of KPMG Europe's International Corporate Tax Group and Jonathan Bridges Senior Manager discuss the ECJ Columbus Containers case
On 6 December 2007 the European Court of Justice (ECJ) delivered its decision in the Columbus Containers DVBA & Co (Case C-298/05) case. It held that although Germany usually exempts foreign profits from German tax it was not contrary to the EC Treaty for this exemption to be overridden where the foreign profits had been subject to foreign tax of less than 30%.
The case has been seen by some commentators as partly restricting or at least going back on the decision in Cadbury Schweppes (Case C-196/04) which held that the UK's controlled foreign company (CFC) rules were unlawful unless only applied...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
