European Taxation

This free e-mail service informs you about the contents of the forthcoming edition of the European Taxation.

Issue No. 8 (2006) of the
European Taxation is now available online.

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Number 8 - 2006 contains the following:

ARTICLES

France

Statement of Practice on Cross-Border Dispute Resolution – France Significantly Improves Tax Security for International Transactions

Bruno Gibert

pp. 355-363

The author analyses the extensive and detailed Statement of Practice, issued by the French tax authorities on 23 February 2006, which integrates the mutual agreement procedures provided for by Art. 25 of the OECD Model Convention and the EC Arbitration Convention of 23 July 1990.

Canada/United States/European Union

Taxation of Corporations in Canada: A Comparison of Tax Burdens with the United States and Selected Member States of the European Union Using the European Tax Analyzer – Part 2

Thorsten Stetter and Christoph Spengel

pp. 364-374

In Part 2 of this article, the authors introduce the concept of the European Tax Analyzer, calculate and compare the effective tax burdens of Canadian corporations, and then extend this comparison to corporations in the United States and 12 selected Member States.

European Union

Commission Communication and General Developments regarding Home State Taxation

Luca Cerioni

pp. 375-382

The author considers the 2005 Commission Communication on Home State Taxation (HST) and the accompanying Working Document.

European Union

Tax Motives Are Legal Motives – The Borderline between the Use and Abuse of the Freedom of Establishment with Reference to the Cadbury Schweppes Case

Nikolaj Vinther and Prof. Erik Werlauff

pp. 383-386

Following the Advocate General's Opinion of 2 May 2006 in the European Court of Justice Cadbury Schweppes case, the authors consider the borderline between the use and abuse of the freedom of establishment.

Ireland

Finance Act 2006 and the Implications for Ireland from a Corporate Tax Perspective

Liam Grimes and Tom Maguire

pp. 387-395

This article provides an overview of the changes contained in the Finance Act 2006, which generally apply from 1 January 2006.

EC UPDATE

CFE NEWS

Opinion Statement on Modernizing Value Added Tax Obligations for Financial Services and Insurances Commission Consultation Paper

pp. 396-398

WHAT'S GOING ON IN ...

Italy

Ruling on the Taxation of Income Derived by Italian Flow-Through Entities