'Marks &Spencer exception'

Attribution of gains to participators in close companies

Avoidance of double taxation by exemption of income of non-resident PE

Case law

Capital and inheritance taxes

Corporation taxes

Double taxation agreements

Income taxes

Compatibility of domestic legislation with EU law

Denial of group income election


Gifts to foreign-controlled companies

Loan interest payments made to related non-resident company

Merger, losses incurred by subsidiary

Profits of establishment, methods of exempting or offsetting tax

Consortium relief

Contributions paid to a savings pension

Costs not deductible of historic building, not listed in State of taxation but listed in State of residence

Deductibility of costs relating to a historic building occupied by its owner

Deduction of loses

Definitive losses

Depreciation of goodwill

Difference in treatment of losses of the recipient company


Controlled foreign companies

Domestic and foreign

Foreign income dividends

Franked investment income

Paid by non-resident subsidiaries

EEA Agreement, interpretation of art. 31

Elimination of double taxation of distributed profits

EU law

Compensation for breach of

Defences to restrictions

Groups of companies

Exemption for group dividends based on residence qualification

Exemption method for dividends distributed by companies in a different member state as the recipient company

Failure of a member state to fulfil obligations

Free movement of capital

French group taxation

Group income election, restriction

Group relief, losses incurred by subsidiaries in other member states

Compatibility of UK provisions with EU law


Interpretation of conditions set out by ECJ

Loss relief for foreign group members

Group taxation

Reincorporation of losses previously deducted in respect of the permanent establishment

Taxation of activity of foreign permanent establishments of resident companies

Imputation method for dividends distributed by company in the same member state as the recipient company

Income tax

Non-resident taxpayer

Tax legislation

Interpretation of art. 43 and 48 EC

Interpretation of art. 49 and 54 TFEU

Interpretation of art. 63 and 65 TFEU

Intra-group financial transfers, deductibility

National corporation tax

Netherlands' tax entity rules in which two or more companies could be treated as single person

Non-deductible costs and expenses related to shareholdings

Non-resident permanent establishment

Obstruction, refusal of deduction for exchange loss


Reclassification of interest payments as taxable dividends

Reference for a preliminary ruling

Request for preliminary ruling on payment of special tax on turnover of store retail trade

Request for preliminary ruling on repayment of taxes levied by a member state in breach of EU law


Capital tax reduction, reserve maintained for next five years

Controlled foreign companies

Offsetting of losses by parent companies

Preservation of allocation of powers of taxation between member states

Shareholders' tax credits

Taxation as group of companies

Restrictions on

State aid

Thin capitalisation

Loan interest payments made to related non-resident company

Loan repayments as covert distribution of profits

Transfer of place of management, taxation of unrealised exchange rate gain

Transfer of residence, unrealised capital gains

Treaty on the Functioning of the European Union (TFEU), art. 49 and EEA Agreement, art. 31

Unusual or gratuitous advantages granted by resident company to company with relationship of interdependence

Wholly artificial constructions

Within the EU