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Tax Cases and Appeals Court of Justice of the European Union
2017-10-26
Corporation tax — Directive 90/435/EEC — Articles 1(2) and 4(2) — Parent companies and subsidiaries of different Member States — Common system of taxation — Deductibility from the taxable profits of the parent company — Domestic provisions seeking to abolish the double taxation of profits distributed by subsidiaries — No account taken of the existence of a link between the interest on loans and the financing of the holding that gave rise to the payment of dividends
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Tax Cases and Appeals Court of Justice of the European Union
2017-10-19
Reference for a preliminary ruling — Taxation — Value added tax (VAT) — Directive 2006/112/EC — Right to deduct — Conditions governing the exercise of that right — Article 273 — National measures — Fight against tax evasion and tax avoidance — Invoice issued by a taxpayer declared ‘inactive’ by the tax authorities — Risk of tax evasion — Refusal of the right to deduct — Proportionality — Refusal to take into account evidence of the absence of tax evasion or tax losses — Limitation of the temporal effects of the judgment to be delivered — No limitation
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Tax Cases and Appeals Crown Copyright
2017-10-16
Income Tax – Losses – appellants were shareholders in companies investing, with the assistance of limited recourse loans, in a general partnership (“Vanguard”) which acquired films from producers under distribution sale and purchase arrangements which included put options held by Vanguard and call options for the producer. Triggers for exercise of options and exercise price dependent on predicted revenue performance according to report made by film valuer shortly after public release of films. Cashflows from exercise of options linked to level of film budget and actual performance of film over time. Whether relief available on shares sold at loss dependent on whether Vanguard carrying on trade (s137 Income Tax Act 2007)? –Vanguard not carrying on a trade – whether loss for capital gains tax purposes? – no – whether HMRC’s enquiries opened under correct statutory provisions? – yes – appeals dismissed
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Tax Cases and Appeals Court of Justice of the European Union
2017-10-12
Reference for a preliminary ruling — VAT — Directive 2006/112/EC — Article 90(1) — Direct effect — Taxable amount — Reduction in the case of cancellation or refusal — Reduction in the case of total or partial non-payment — Distinction — Financial leasing agreement terminated for non-payment of public charges
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