Anton Hume International Tax Partner Grant Thornton examines the taxation of UK companies on dividends from EU subsidiaries
There has been much debate in recent years about whether aspects of UK tax statute are consistent with European law.
In this article I will consider whether the taxation of UK companies on dividends from European Union (EU) companies but not on dividends from UK companies infringes the EC Treaty. If this is so UK statute can be put aside as a mistake of law and litigation against the Revenue for restitution of tax as addressed in the Deutsche Morgan Grenfell decision could result. Indeed a Group Litigation Order has recently been made in relation to amongst other issues this very matter.
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Anton Hume International Tax Partner Grant Thornton examines the taxation of UK companies on dividends from EU subsidiaries
There has been much debate in recent years about whether aspects of UK tax statute are consistent with European law.
In this article I will consider whether the taxation of UK companies on dividends from European Union (EU) companies but not on dividends from UK companies infringes the EC Treaty. If this is so UK statute can be put aside as a mistake of law and litigation against the Revenue for restitution of tax as addressed in the Deutsche Morgan Grenfell decision could result. Indeed a Group Litigation Order has recently been made in relation to amongst other issues this very matter.
...
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