There were a number of important EU developments over the last month, most notably the High Court decision in the Prudential case (part of the CFC and dividend GLO) looking at the taxation of portfolio dividends. There were also two AG opinions covering consortium relief and the taxation of dividends to third country investment funds. Elsewhere, there are important changes in Brazil to bring the tax rules into line with IFRS, the changes to the Irish company residence rules have now been published in the Finance Bill, and Norway is pressing ahead with very restrictive interest limitation rules.
