Mark Whitehouse Tax Litigation Reynolds Porter Chamberlain LLP looks at some significant ECJ decisions that have an impact on the UK's relations with non-EU Member States
Peter Cussons1 has looked in his article at the effect of a number of decisions of the European Court of Justice on the UK tax regime and its competitiveness. In this article I am considering recent decisions that have an impact on the UK's relations with non-EU Member States. There have been several significant cases and it is now possible to extract some general principles. The decisions involve either bilateral double tax conventions with the UK or the EC Treaty; in common the cases all involve attempts to extend EU non-discrimination arguments to enterprises outside the EU.
If you are not a subscriber, subscribe now to read this content.
Mark Whitehouse Tax Litigation Reynolds Porter Chamberlain LLP looks at some significant ECJ decisions that have an impact on the UK's relations with non-EU Member States
Peter Cussons1 has looked in his article at the effect of a number of decisions of the European Court of Justice on the UK tax regime and its competitiveness. In this article I am considering recent decisions that have an impact on the UK's relations with non-EU Member States. There have been several significant cases and it is now possible to extract some general principles. The decisions involve either bilateral double tax conventions with the UK or the EC Treaty; in common the cases all involve attempts to extend EU non-discrimination arguments to enterprises outside the EU.
If you are not a subscriber, subscribe now to read this content.