UK Group Transfer Rules tested before the ECJ
In a reference for a preliminary ruling from the UK Upper Tribunal the European Court of Justice (ECJ) is asked whether the immediate tax charge on a transfer of assets from a UK resident company to a sister company resident in Switzerland (which does not carry on a trade in the UK through a permanent establishment) contrasts with EU-Law (Article 49 TFEU or Article 63 TFEU).
Kategorien: European Court of Justice
Schlagwörter: Knowledge Transfer (KT) / Wissenstransfe ...
