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International briefing for June 2014

Speed read

As widely reported, the EC has opened a state aid investigation into tax rulings granted to Apple, Starbucks and Fiat. There have been two interesting cases at the CJEU involving legislation in the Netherlands: the first looks at the Dutch tax consolidation rules; and the second considers the legality of withholding tax on dividends paid to the Netherlands Antilles. The Singapore tax authorities have issued guidance on the tax treatment of hybrid instruments. Some interesting proposals have been put forward in Sweden on the tax deductibility of financing expenses and in Poland draft legislation for the new CFC rules has now been published.

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