Court of Justice of the European Union
Gallaher Ltd
v
Revenue and Customs Commissioners
(Case C‑707/20)
EU:C:2023:101
2022 Sept 8; 2023 Feb 16
President of Chamber K Jürimäe,
Judges M Safjan, N Piçarra, N Jääskinen, M Gavalec
Advocate General A Rantos
RevenueCapital gains taxTransfer of assets between companies in same groupUnited Kingdom-resident taxpayer indirect subsidiary of Netherlands company with direct Swiss subsidiaryTaxpayer making disposals of assets to Swiss sister and Netherlands parent companiesWhether transfer of assets between companies giving rise to capital gains charge with no right to defer payment under United Kingdom legislationWhether legislation within scope of European Union right to free movement of capitalWhether legislation restricting freedom of establishment of parent companyWhether restriction necessary and proportionate Taxation of Chargeable Gains Act 1992, s 171 Corporation Tax Act 2009, ss 775, 776 FEU Treaty , arts 49, 63
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