Corporate

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• Increased focus of tax authorities on transfer pricing valuation

  Article

  Submitted: 08 August 2018

  ​Clive Jie-A-Joen, Liu Lu and Fan Bai examine recent TP developments that are relevant for the arm's-length pricing of transactions of intangibles and other items of value between group entities resulting from business restructuring. Each of these developments is specific and can be useful considering the specific facts and circumstances of the case at hand.

• Advances to company with no immediate prospect of repayment still loan relationships

  Article

  Submitted: 02 August 2018

  Advances made to a company with no immediate prospect of repaying either the monies or interest on those monies were still loan relationships where they were properly contractually documented as loans.

• Overpaid tax on portfolio dividends: remedies and interest

  Article

  Submitted: 26 July 2018

  The Supreme Court has held that EU law required the UK to give credit against UK tax on foreign portfolio dividends based on the nominal rate of tax in the jurisdiction of the distributing company, but that neither EU nor UK law requires the payment of compound interest on repayments.

• Un redressement en matière de prix de transfert peut-il avoir une incidence sur la CVAE ?

  Article

  Submitted: 26 July 2018

  ​Un redressement en matière de prix de transfert peut avoir une incidence automatique sur la CVAE, selon le Conseil d’Etat.

• VAT and holding companies: involvement in the management of a subsidiary

  Article

  Submitted: 25 July 2018

  A holding company making taxable supplies of property to a subsidiary was involved in the management of that subsidiary and was able to obtain input VAT recovery in relation to costs incurred in acquiring its shareholding in that subsidiary.

• Loss streaming necessary on succession to trade

  Article

  Last Reviewed: 29 June 2018 / Submitted: 29 July 2016

  A taxpayer that acquired a loss making company and succeeded to its trade was only entitled to set the carried-forward trading losses from the acquired trade against the trading profits from that same trade.

• Danish withholding tax on dividends to foreign funds contrary to EU law

  Article

  Submitted: 28 June 2018

  Withholding tax on dividends paid to a foreign fund was contrary to the free movement of capital, in circumstances where domestic distributing funds were exempted from withholding.

• Commercial and practical approach required to determining source of interest

  Article

  Submitted: 25 June 2018

  The Court of Appeal has stressed the need for a commercial and practical approach to the multifactorial test of determining the source of interest when applying the UK withholding tax provisions.

• A Luxembourg IP box tax regime in a BEPS fashioned way

  Article

  Submitted: 18 June 2018

  An article published in the June 2018 edition of “AGEFI Luxembourg” on Luxembourg’s replacement IP box.

• ECJ confirms Marks & Spencer ruling on cross-border losses applies to permanent establishments

  Article

  Submitted: 15 June 2018

  The ECJ has applied the principles set out in its 2005 Marks & Spencer ruling to the final losses incurred by a permanent establishment of a Danish company located in Finland, notwithstanding the option of an international joint taxation regime in Denmark.

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