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By Nadeem Khan, Melissa Moyle
In the prevailing economic conditions tenants will review and consider the terms of their leases more closely than perhaps was the case previously, trying to find ways to reduce liabilities attaching to their occupation of their properties.
By Simon Whitehead
The hearing before the Special Commissioners concluded on 27th February. Although the case has limited remaining impact for other similar claims, the trial did tease out HMRC’s current reading of the ECJ’s decision of Dec ’05.
By Simon Whitehead
Sweden operates a system under which a company may make a group contribution to another company. The group contribution is deducted from the taxable profits of the contributing company and is accounted for as taxable income by the recipient company.
By Richard Chao, Haidong Yang
The amended PRC Provisional Regulations on Business Tax (Provisional Regulations) and the PRC Implementation Rules for Provisional Regulations on Business Tax (Implementation Rules) both took effect on January 1, 2009.
By Mark Taylor, Clara Eisenberg
The Association of British Insurers has recently issued new guidance on the extent of the general allotment authority (under s.80, Companies Act 1985) which it regards as acceptable for listed companies.
By Nadeem Khan, Kathrin McClintock
Stamp Duty Land Tax was introduced on 1 December 2003. An SDLT anti-avoidance rule applies, if, following the end of the fifth year of the term of a lease the amount of rent payable under the lease increases by an abnormal extent.
By Anastasia Fowle, Ron Moscona
Trade marks with a reputation enjoy an extended form of protection in the European Union.
By Bernd Graf
A recent EU initiative provides funding for European VC funds investing in, and guarantee facilities to banks making loans to, SMEs in Europe.
By Kelly Coutinho
Revenue & Customs Brief 33/08 (28 July 08) announced a consultation on changes to the corporate tax rules on late payment of interest between connected companies.
By Philippe Freund
The French fiscal integration provisions give French groups of companies the right to an election which allows the ultimate parent to take into account all of the profits and losses of the group companies.
By Simon Whitehead
In Finance Act 2006 the UK introduced changes to the group relief rules, ostensibly to ensure compliance with the judgment in the Marks & Spencer case. Many commented, including ourselves, that those changes reflected an overly restrictive interpretation of the judgment and would only give the ability to exercise group relief for cross border losses in extremely rare cases.
By Simon Whitehead
Paul Farmer, the former Head of DG Taxud's Tax Policy Unit, gives his personal take on the news.
By Colina Greenway
Essential reading for organisations that employ non EU nationals in their UK workforce. From 1 November the current work permit scheme will be replaced with a new points-based qualifying system.
By Dorsey London Department
This is a decision concerning some of the benefits which attach to claimants who participate in group litigation orders as opposed to watching them from the sidelines.
By Dorsey London Department
In the “Daily Mail” case, the Court had concluded that provisions regarding the life and death of a company were determined solely by the Member State under whose laws the company was created.