The ECJ has ruled illegal under European Union law discriminatory national
rules imposing more taxation on foreign European Union shareholders than is paid
by domestic shareholders.
Judges found for a French national Margaretha Bouanich, who received 917,000
euros from a Swedish public limited company, Förvaltnings AB Ratos, which had
decided to reduce its share capital. She launched legal action after the Swedish
local tax board, the Skatteverket, subsequently refused to refund tax charged on
her earnings from the repurchase.
Under Swedish regulations, non-resident shareholders cannot deduct the
initial cost of buying repurchased shares as an allowable business expense,
while those resident in Sweden can. The ruling is a legal precedent in all EU
member states, including Britain.
Richard Le Tocq, head of Locate Guernsey, discusses the chancellor’s approach to high net worth individuals, and why relocation is increasingly attractive to HNWIs
The firm says that the U-turn 'does not alter the need for a fundamental review of the way we tax work' and that the current tax system is in need of reform
Legislation on the NICs changes to be brought forward in the autumn following publication of 'the full effects of the changes to Class 2 and Class 4' in the summer
Following chancellor Philip Hammond’s Spring Budget speech, we explore the key takeaways for businesses and individuals