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EU TAX LITIGATION

EU TAX LITIGATION. David Ewart QC Pump Court Tax Chambers 16 Bedford Row London WC1R 4EF Tel: 0207 414 8080 clerks@pumptax.com. ACT GLO. Class 1: Hoescht ; DMG ; Sempra Class 2: Pirelli Class 3: Boake Allen Class 4: ACT Class IV ; Pirelli. LOSS RELIEF GLO. Autologic

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EU TAX LITIGATION

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  1. EU TAX LITIGATION David Ewart QC Pump Court Tax Chambers 16 Bedford Row London WC1R 4EF Tel: 0207 414 8080 clerks@pumptax.com

  2. ACT GLO Class 1: Hoescht; DMG; Sempra Class 2: Pirelli Class 3: Boake Allen Class 4: ACT Class IV; Pirelli

  3. LOSS RELIEF GLO Autologic Marks & Spencer No possibilities test Multiple claims Time Limits Computation of losses

  4. FII GLO Denial of FII on foreign dividends Corporation tax on foreign dividends FIDs Third country claims Restitutionary claims Sufficiently serious breach TMA 1970 section 33 Time limits

  5. THIN CAP GLO Compatibility of thin cap provisions Lankhorst; SGI Third country claims Sufficiently serious breach

  6. CFC AND DIVIDEND GLO CFC: Cadbury Schweppes; Vodafone 2 Portfolio dividends Nature of relief Insurance company issues Third country; double tax treaties

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