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Japanese Business Taxation Europe - Vol 30


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March 2012

In this issue of the JBTE newsletter the following topics are covered:

Belgium

  • European Commission asks Belgium to expand scope of application of notional interest deduction
  • New anti-abuse provision proposed under 2012 budget

Denmark

  • Tax authorities lose another beneficial ownership case
  • Draft corporate tax bill announced

EU

  • ECJ clarifies concept of "valid commercial reasons" in Merger Directive

Finland

  • Change-in-control rules referred to ECJ on state aid grounds

France

  • Amended 2012 budget law approved

Germany

  • tax authorities issue guidance on amended anti-treaty shopping rule

Ireland

  • Finance Bill 2012 generally positive for companies

Italy

  • Austerity package enacted
  • Optional exit tax deferral introduced for deemed gains on intra-EU/EEA migration

Luxembourg

  • Luxembourg asked to amend VAT rules on independent groups
  • Luxembourg improves the environment for private investors
  • Court clarifies tax treatment of share subscription rights
  • Specialized Investment Fund law ready for AIFMD

Malta

  • 2011 Tax developments

The Netherlands

  • important jurisprudence regarding beneficial ownership

Spain

  • Tax measures introduced to tackle public deficit

UK

  • CFC Reform: Consultation Update

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