Tax weekly highlights—7 March 2019

Table of contents

• International
• EU tax advantages denied by abuse of rights principle on its own (N Luxembourg 1 and T Danmark)
• Free movement of capital and CFC-type legislation (X GmbH v Finanzamt Stuttgart-Koerperschaften)
• Income tax exemption and non-UK pension funds (BAV-TMW-Globaler- Immobilien Spezialfonds v HMRC)
• Update to International Manual
• HMRC publishes DTT priorities for 2019
• HMRC confirms UK/Lesotho DTT is in force
• CIOT comments on draft guidance on provisions charging gains accruing to non-residents
• European Parliament TAX3 Committee publishes final report
• Spring Statement 2019

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Article summary

This week’s edition of Tax highlights includes: (1) the decision of the Court of Justice in the joined cases of N Luxembourg 1 and T Danmark on the EU abuse of rights principle and its application to improper use of EU directives, (2) the decision of the Court of Justice in X GmbH on whether German CFC-type legislation, to the extent it applied to investments into third countries, was ‘grandfathered’ or represented an unjustifiable restriction on the free movement of capital, and (3) predictions and planned coverage for Spring Statement 2019.