Controlled Foreign Corporation rules are a hot issue in Europe and beyond. Last year, EU countries agreed to have national CFC rules in force by 2019. The Big Four - Germany, France, Italy and Spain …
The decision of the CJEU in Republic of Austria v Federal Republic of Germany (Case C-648/15) on 12 September 2017 is a landmark decision in tax treaty dispute resolution. Han Verhagen raised…
On 12 September 2017, the CJEU confirmed that it has jurisdiction over a dispute between Austria and Germany regarding the interpretation of a double tax convention entered into between the two…
The objective of the EU Merger Directive (“MD”) is to remove tax obstacles to cross-border restructuring operations while safeguarding the financial interests of the Member States.[1] In aligning…
This contribution lays down a general plan for what the EU should do in order to attain a harmonized set of norms regulating the allocation of taxing rights among Member States and in the relation…
Intermediaries (such as: tax advisors, accountants, banks, and lawyers) who design tax structures are now on the Commission’s radar. She recently proposed extensive transparency rules on the basis of…
The Committee on Economic and Monetary Affairs and the Committee on Civil Liberties, Justice and Home Affairs of the European Parliament recently finalized the amendments to the existing Anti-Money…
On 21 June 2017, the European Commission released its Proposal on transparency rules for tax intermediaries. It primarily seeks to address concerns raised by the ECOFIN Council and the European…
An analysis from a State Aid perspective.
This contribution focuses on the profit split methodology in light of current EU Commission’s investigations in the area of tax rulings and transfer pricing…
