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الصفحة 392
The file shows that , rather than putting before the court an issue involving a difference in treatment between , on the one hand , ultimate shareholders , whether or not resident , receiving dividends paid by a resident company and ...
The file shows that , rather than putting before the court an issue involving a difference in treatment between , on the one hand , ultimate shareholders , whether or not resident , receiving dividends paid by a resident company and ...
الصفحة 395
In the present case , it is not disputed that a company resident in the United Kingdom which receives dividends from another resident company is entitled to a tax credit in that member state , equal to the fraction of the amount of the ...
In the present case , it is not disputed that a company resident in the United Kingdom which receives dividends from another resident company is entitled to a tax credit in that member state , equal to the fraction of the amount of the ...
الصفحة 399
It follows that legislation of a member state which , on a payment of b dividends by a resident company where no DTC is involved , grants a tax credit equal to the fraction of the advance corporation tax paid by the company making the ...
It follows that legislation of a member state which , on a payment of b dividends by a resident company where no DTC is involved , grants a tax credit equal to the fraction of the advance corporation tax paid by the company making the ...
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accordance action activities adopted agreement application authorities basis benefits cited in footnote citizens claims Commission Community law concerned considered constitute contracts Council Court of Justice decision determine Directive discrimination dividends EC Treaty economic effect elections employer employment entitled established European European Parliament exercise fact fees formerly freedom Germany grant grounds income infringement interests interpretation issue Italy judgment justified lawyers legislation limited main proceedings meaning measures movement national court necessary Netherlands objective obligation observations opinion para paras particular parties period persons possible present principle procedure prohibition protection question reasons referred regard Regulation relating relationships relevant resident respect restriction result rules situation social specific submitted subsidiary taxation territory Treaty undertakings Union United Kingdom vote workers