On February 20, 2007, U.K. retail giant Marks & Spencer won a key ruling from the Court of Appeal in a tax dispute over when foreign losses can be offset by domestic profits. The court mostly confirmed a 2005 European Court of Justice ruling and overturned a U.K. law that permitted losses of U.K.-based subsidiaries, but not losses of foreign subsidiaries, to offset a U.K. parent company's income.
Also in this issue:
- Belarus
- New laws aim to simplify tax system.
- European Union
- European Commission to challenge Swiss cantonal tax regimes.
- German withholding tax applied to non-resident service providers.
- AG opines on anti-abuse provisions in merger directive.
- France
- Tax authorities issue guidance on CFC rules.
- Germany
- Update on reform plans.
- Hong Kong
- 2007/2008 budget delivered.
- IRD rules on “form-over-substance” principle.
- Hungary
- Minimum tax abolished.
- New decree issued on grants and incentives for strategic investments.
- Indonesia
- Withholding tax rules on services amended.
- Netherlands
- State aid developments relating to group interest box and patent box.
- New Zealand
- Draft ruling issued on legal services provided to non-residents.
- Poland
- PEs now qualify for APAs.
- Portugal
- New rules restrict VAT exemption on immovable property.
- Singapore
- 2007 budget targets enhancement of business and investment.
- South Africa
- Secondary tax on companies to be phased out.
- Sweden
- Abolition of exit taxation of stock options proposed.
- Switzerland
- New federal law to replace bonny decree.
- New VAT law proposed.
- Ukraine
- Higher administrative court rules on VAT tax credit.
- United Kingdom
- Swiss Bank’s tax credits claim under non-discrimination article overturned.
- United States
- Treasury rewrites “GRA” rules for outbound stock transfers.
- Treaty signed with Bulgaria.
- Uruguay
- Transfer pricing rules introduced.