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Is there an EU-compliant corporate tax system?

Category Technical Articles
AuthorTechnical Department
Article by John Cullinane, Chairman, CIOT Corporate Tax Sub-Committee. This article appeared in the March 2004 issue of Tax Adviser. The government's proposals to extend transfer pricing legislation to intra-UK transactions (and import thin capitalisation rules into that extension) - in order, it says, to 'put beyond doubt' its compatibility with European Union obligations, raise a number of questions. Is this just the tip of the iceberg? Will a whole range of UK-to-UK reliefs - group relief for examply - come under threat if future European Court of Justice decisions create further 'doubts'? Is the ECJ an inevitably destructive force, striking down offending national provisions, but unable (in the absence of support for harmonisation among the member states) to construct workable rules for an EU-compliant tax system?

To download the article in Adobe (pdf) format, please click on the link below.

Technical Department
020 7235 9381

March 2004 by John Cullinane


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