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ARTICLES
The Jurisprudence of the European Court of Justice: Limitation of the Legal Consequences?
Prof. Dr Roman Seer
pp. 470-477
In this article, the author considers the concept of restricting the legal consequences of the decisions of the European Court of Justice. This issue is of particular relevance as it has been raised in recent Opinions of the Advocates General.
Partnerships and Other Hybrid Entities and the EC Corporate Direct Tax Directives
Raffaele Russo
pp. 478-486
The purpose of this article is to demonstrate how the EC Directives on direct corporate taxation deal with the issues arising from the use of partnerships and other hybrid entities in an EC context and to highlight some of the unresolved problems. The article, therefore, considers and comments on the provisions in the EC Parent-Subsidiary, the Interest and Royalties and the EC Merger Directives in relation to this topic.
Germany
The (In)compatibility of the German LLC Decree on the Classification of Foreign Entities with the German Domestic Legal Framework and EC Law
G.K. Fibbe
pp. 487-495
In this article, the author first comments on the LLC Decree regarding the classification of foreign entities. He then describes the classification of domestic entities under German law and of entities established under foreign private law, and considers the compatibility of the method adopted in the LLC Decree with the German national framework and EC law.
United Kingdom
Domicile and the Remittance Basis in UK Taxation
pp. 496-503
The author provides a comprehensive description of the significant factors relating to the remittance basis in relation to UK taxation. This includes comments on the background to the remittance basis, the person affected, establishing domicile, the remittance basis itself and the practicalities relating to the remittance basis, relief for double taxation, and source country taxation.
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EC UPDATE
WHAT'S GOING ON IN…
Denmark
Denmark Extends Scope of Anti-Avoidance Rules
Nikolaj Bjørnholm and Anne Becker-Christensen
pp. 504-505
The authors describe the new Danish anti-avoidance rules that are intended to counter debt-leveraged acquisitions of Danish companies by certain foreign investors.
European Union/Netherlands
EC Law versus Dividend Withholding Tax Imposed on Inbound and Outbound Dividends
Han J. Oortwijn
pp. 506-510
The author reports on the fourth Amsterdam Center for International Law Seminar on International and European Taxation held in June 2006, at which noted commentators considered the implications of various cases before the European Court of Justice and the Court of Justice of the European Economic Area, and the proposed Netherlands legislation in relation to dividend withholding tax on inbound and outbound dividends.
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