The Interest Limitation Rule of the Proposed EU Anti-Tax Avoidance Directive:...
Loyens & Loeff Introduction On 28 January 2016, the proposal for a council directive laying down rules against tax avoidance practices that directly affect the functioning of the internal market...
View ArticleEU BEPS / Taxing Low-Taxed Non-EU Income: Think Twice…
Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff (about the switch-over clause in the ATA Directive) In order to combat BEPS, the European Commission is proposing...
View ArticleThe Commission Proposal for an Anti-BEPS Directive: Some Preliminary Comments
Luxembourg University 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...
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Will the US Impose Double US Tax Rates on EU Companies from Countries that...
Texas A&M University Law On January 15, 2016, in a joint (bi-partisan) letter of Senate Finance Committee Republicans and Democrats to US Treasury, one that will certainly be of interest to our...
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Fifty shades of fair exit taxation of corporations
Mircea and Partners Law Firm The raison d’être of corporate taxation relates to the aim of achieving an impartial treatment of different legal forms in order to safeguard a level playing field for...
View ArticleDarwin & Corporate Taxation – Has the Evolution of the Economy Killed the...
CORIT advisory Written by Associate Professor, PhD, Michael Tell, Department of Law, Copenhagen Business School and Technical Advisor, CORIT Advisory. Darwin’s theory of evolution states that complex...
View ArticleHow much would Starbucks pay me for coffee?
Independent International Tax Professional Introduction It has been a few weeks now since the Commission has made public its decisions in the FIAT and Starbucks cases. I understand that the...
View ArticleWhy a 1999 EU study was kept a secret till now: France made tax deals outside...
Dorean Global Tax Policy BV The 1999 Simmons & Simmons report on administrative practices is now public, together with the responses by Member States. My suspicion was correct: France had reason to...
View ArticleThe Interplay between the State Aid Rules and other BEPS-Preventing Tools...
Mircea and Partners Law Firm 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...
View ArticleCould I Please Get a Fiat for the Price of my Frappuccino?
Maastricht University 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...
View ArticleSame Same But Different. A misunderstanding of the EU tax jurisprudence with...
Mircea and Partners Law Firm 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...
View ArticleWhat Women and the Institutions of the EU Have in Common
Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam As a woman, I naturally think that women are wonderful creatures. We are sociable, charming, caring and (almost) always the radiant...
View ArticleDouble or quits jeopardy? A quest for procedural justice in VAT fraud cases.
Mircea and Partners Law Firm 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...
View ArticlePractical Issues of the Anti-Hybrid Rule in the Parent Subsidiary Directive
Mariz de Oliveira e Siqueira Campos Advogados 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...
View ArticleTo engage or not to engage, is that the question?
Independent International Tax Professional 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...
View ArticleDual residence and the right to migrate under EEA law (Arcade Drilling).
Mircea and Partners Law Firm 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...
View ArticleWhy Europe needs 3CTB to get ahead
Independent International Tax Professional 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...
View ArticleThe New Common Anti-Abuse Rule in the EU Parent-Subsidiary Directive is a ‘De...
Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff Due to an amendment of the EU Parent-Subsidiary Directive, the EU Member States must include a common minimum...
View ArticleEffective Tax Rates in Multinationals and Domestic Firms
CORIT advisory There are a lot of opinions on multinationals and their tax practices. One conventional perception is that multinationals have a general tax advantage over their domestic competitors as...
View ArticleIs there such a thing as definitive losses? And if so, when? – Part 2
Luxembourg University 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...
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