UK Taxation Summit

This LexisNexis conference chaired by John Whiting Tax Partner at PricewaterhouseCoopers explored recent international and domestic tax developments. David Varney Executive Chairman of HMRC delivered the closing address.

Charles Hellier Tax Partner at Linklaters spoke about recent EC cases. In Manninen the ECJ held that it was unlawful to restrict a tax credit to domestic dividends although the Advocate-General had rejected the argument that the cohesion defence can only apply if the same person enjoying the tax advantage suffers the offsetting fiscal levy. Whether the defence can actually be made out depends upon the objective being pursued. Here it was to prevent...