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ARTICLES
Germany
The Introduction of a German Real Estate Investment Corporation
Dr Petra Eckl and Marcus Seiboth
pp. 3-12
The authors first outline the background to the introduction of the German Real Estate Investment Corporation (G-REIT) regime. They then consider the corporate law characteristics of G-REITs. Next, the taxation of G-REITs and their shareholders is described, together with the implications for the German controlled foreign company rules. The authors conclude with a consideration of the potential incompatibilities of the new G-REIT regime with EC law.
European Union
Cadbury Schweppes: The ECJ Significantly Limits the Application of CFC Rules in the Member States
Prof. Dr Gerard T.K. Meussen
pp. 13-18
In this article, the author analyses the important European Court of Justice judgment in the recent Cadbury Schweppes case regarding the compatibility of controlled foreign company legislation with EC law.
The Implications of the Walter Stauffer Case for Charities, Donors and Governments
Dr Sigrid J.C. Hemels
pp. 19-24
This article considers the decision of the European Court of Justice in the Walter Stauffer case, the implications for donors and charities, the possible legislative changes, and whether or not the ECJ's judgment is relevant to charities located in third countries and/or European Economic Area Member States.
European Union
The ECJ's Decision in the Senior Engineering Investments BV Case
Raf Bogaerts
pp. 25-29
European Union
Multistate Cumulative Tax Burdens and Reliefs in the European Community – Lessons from the United States
pp. 30-37
The author starts by examining the implications of cumulative tax burdens and reliefs in a multistate scenario in the United States and then examines the same issues in a Community context. Next, the implications of tax treaties are scrutinized. Finally, the author considers whether or not the apparent Community asymmetry regarding this issue is about to be corrected.
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European Union/Germany
Earnings Before Interest (EBIT) instead of Profits as a Tax Base?
Prof. Dr Lorenz Jarass and Prof. Dr Gustav M. Obermair
pp. 38-46
In this article, the authors examine the threat that, in their opinion, income tax base erosion poses to the German economy. They then consider the danger that German government tax policies could have for the public finances. The authors conclude by arguing for a tax on all compensation for capital as (part of ) a solution to these problems.
United Kingdom/International
Do UK Tax Planning Disclosure Developments Imply a General Change of Approach by Tax Authorities?
Simon Wilks, Alan Arenstein and Phil Greenfield
pp. 47-50
The authors consider the background to this issue, disclosure regimes and international cooperation, the Seoul Declaration of September 2006 and its implications for disclosure regimes, and the changes to the United regime that have effect from 1 August 2006.
EC UPDATE
CFE NEWS
Opinion Statement of the CFE Task Force on ECJ Cases on the Judgment in the Case of Marks & Spencer plc v. Halsey (Case C-446/03) – Judgment Delivered 13 December 2005
pp. 51-54
WHAT’S GOING ON IN ...
Italy
Deemed Italian Tax Residence for Foreign Holding Companies
Giuseppe Campolo
pp. 55-57
Russia
Amendments to the Russian Tax Code Promulgated
pp. 58-59
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