EU/EEA

According to EU law the prevailing divergences between the national tax systems shall not be corrected by unilateral measures that grant fiscal advantages to firms, which are affected by the…

Today the European Commission released its first set of decisions on corporate tax rulings, which it has investigated for over a year. Starbucks Manufacturing EMEA and Fiat Finance and Trade were the…

The scope of the present article will be narrow. The aim is to point out a misinterpretation of the Cadbury ruling, which might have caused a flawed theory of the compatibility of certain CFC regimes…

As a woman, I naturally think that women are wonderful creatures. We are sociable, charming, caring and (almost) always the radiant center of attention. But unfortunately we are accused of having a…

The establishment of a link between the financial interests of the Union and the general budget of the Union is the reason why the domestic penalties made applicable in matters of VAT fraud are…

In a recent post, Professor Werner Haslehner raised an interesting discussion on the new wording of Article 4.1 (a) of the Parent-Subsidiary Directive (“PSD”), which obliges the Member State of the…

This is another lone voice cry in the wilderness – I am getting used to that. By 9 September 2015, anyone who has an opinion about further corporate tax transparency in Europe, are invited to file it…

The case brings about the opportunity to fill a gap in the Norwegian tax law. In order to determine the fiscal residence of a corporation, the current formula stipulated by art. 2(2) Tax Act uses the…

On 17 June 2015, the Commission adopted a plan to relaunch the 3CTB (Common Consolidated Corporate Tax Base), a common system for calculating the tax base of businesses operating in the EU.  Except,…