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Notes:
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CORPORATION TAX – whether the UK legislation in relation to intra-group disposals is compliant with EU law – consideration of the applicable freedoms, whether or not the provisions in question restrict a freedom, whether or not the provisions can be justified by the lack of objective comparability of situation or by reference to the balanced allocation of taxing powers between Member States, the proportionality of the restriction, the doctrines of conforming interpretation and disapplication – consideration of movements of capital – in relation to the disposal of shares to the Dutch resident parent company, disapplication of the restriction limiting no gain/no loss disposals to transferees within the UK tax net – in relation to the disposal of intangible assets to the Swiss resident sister company, UK legislation compatible with EU law |
