Freedom of establishment
'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
Generally
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
Dividends
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
Generally
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
Generally
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
Proportionality
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
Restriction
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
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
