Market leading insight for tax experts
View online issue

Direct Tax Cases in 2008

 
Alan Dolton editor of Tolley's Tax Cases reviews some of the leading direct tax decisions reached during 2008
 
The ECJ delivered an important judgment in Test Claimants in the CFC and Dividend Group Litigation v CIR. The ECJ held that Articles 43 and 48 of the EC Treaty 'must be interpreted as precluding the inclusion in the tax base of a resident company established in a Member State of profits made by a controlled foreign company in another Member State where those profits are subject in that State to a lower level of taxation than that applicable in the first State unless such inclusion relates only to wholly artificial arrangements intended to escape the national tax normally payable. Accordingly such a tax measure must not be applied where it is proven...
If you are not a subscriber, subscribe now to read this content.
If you are already a subscriber, sign in
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
EDITOR'S PICKstar
Top