Simon Whitehead partner Dorsey & Whitney discusses the pending European cases involving the tax treatment of transactions with companies with their seat outside the EU
Since at least 19861 corporation tax has been a target for the application of European Community law. If the European Court adopts the approach of its Advocate-General in the Marks & Spencer case it might even be said that we have now entered an era of EU-wide coherence in the operation of Member States' corporation tax systems.2 The next question to be addressed is how those principles designed for the operation of a Single Market should be applied to the tax treatment of transactions with companies with their seat in countries beyond the EU or 'third countries' as they are known in Euro-parlance.
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Simon Whitehead partner Dorsey & Whitney discusses the pending European cases involving the tax treatment of transactions with companies with their seat outside the EU
Since at least 19861 corporation tax has been a target for the application of European Community law. If the European Court adopts the approach of its Advocate-General in the Marks & Spencer case it might even be said that we have now entered an era of EU-wide coherence in the operation of Member States' corporation tax systems.2 The next question to be addressed is how those principles designed for the operation of a Single Market should be applied to the tax treatment of transactions with companies with their seat in countries beyond the EU or 'third countries' as they are known in Euro-parlance.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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