On February 25, 2010 the European Court of Justice issued its ruling in X Holding (C-337/08 X Holding Judgment.pdf). Under the facts of the case, a Dutch parent wanted to be allowed to combine with its Belgian subsidiary under the Dutch tax consolidation rules to use the latter losses, which it would have been
New corporate tax form for 2009 implements new provisions on deduction of interest expenses within the tax consolidated group…
Continue Reading The New Consolidated Corporate Income Tax Form for 2009 Addresses Interest Deduction Limitations in Consolidated Groups
Italian tax administration rules that EU merger does qualify for tax free treatment under the EU merger directive if no permanent establishment in Italy exists after the merger…
Continue Reading EU Outbound Merger Not Eligible For Tax-Free Treatment if No Permanent Establishment in Italy After the Merger
European Court of Justice in Société Papillon (C-418/07) ruled that French national laws that limit access to tax consolidation in EU cross-border situations violate the EC Treaty. The ruling offers taxpayers opportunities to claim access to consolidation at the EU level every-time that such option is granted at domestic level and to offset losses and profits of the EU members of a consolidated group.
Continue Reading ECJ Ruled That Restrictions to Tax Consolidation Violate EC Treaty