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Jonathan Schwarz has already briefly discussed the CJEU’s judgment in the “Danish Beneficial Ownership Cases” (C-115/16, C-118/16, C-119/16, C-299/16 and C-116/16 and C-117/16), noting that the cases…

Following up on Jonathan Schwarz’s latest blog contributing to the debate on taxation and value creation, I wanted to attempt adding some further critical points. The OECD’s stated goal of the second…

On 24 August 2016, the US Treasury Department issued a White Paper on “The European Commission’s Recent State Aid Investigations of Transfer Pricing Rules” (the “White Paper”), denouncing the…

On 6 June 2016, the European Commission finally released its decision in the McDonald’s State Aid case. After the clarifications recently provided on the Commission’s position concerning transfer…

On 28 January 2016, the European Commission issued its proposal for a Council Directive dealing with tax avoidance practices within the EU – the so-called Anti-BEPS Directive. The context of the…

Since the press releases confirming negative State Aid decisions in the Starbucks and Fiat tax ruling cases late October, the EU tax law community is still eagerly awaiting the publication of the…

Last month, Dennis Weber started a debate on recent BEPS-related changes to European tax directives with his post on the General Anti-Abuse Rule in the Parent-Subsidiary. I would like to follow up on…

Following my latest post on the Court of Justice’s decision in Commission v UK (C-172/13, ECLI:EU:C:2015:50), I want to turn in this comment on the related issue of currency losses, which was…

Two cases recently discussed by the European Court of Justice provide a welcome opportunity to use this space for a quick review of the status of foreign loss relief under EU law. The first is the…