International update

The High Court has agreed to a Group Litigation Order following the HSBC Holdings Ltd case on Stamp Duty Reserve Tax. The ECJ decision in Etablissements Rimbaud may not have such wide implications as was originally envisaged. In the joined cases of Haribo and Salinen the Advocate-General applied a test, not previously used in dividend cases, that a domestic rule must be applied in a coherent manner. The European Commission is continuing infringement proceedings against three Member States regarding exit taxes. Groups with operations in France, Austria or Italy may wish to consider pre-year end actions as a result of proposed and actual tax changes.