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Columbus Containers Services

Chris Morgan, UK Head of KPMG Europe's International Corporate Tax Group, and Jonathan Bridges, Senior Manager, discuss the ECJ Columbus Containers case

 
Chris Morgan UK Head of KPMG Europe's International Corporate Tax Group and Jonathan Bridges Senior Manager discuss the ECJ Columbus Containers case
 
On 6 December 2007 the European Court of Justice (ECJ) delivered its decision in the Columbus Containers DVBA & Co (Case C-298/05) case. It held that although Germany usually exempts foreign profits from German tax it was not contrary to the EC Treaty for this exemption to be overridden where the foreign profits had been subject to foreign tax of less than 30%.
 
The case has been seen by some commentators as partly restricting or at least going back on the...

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