Number 7 - 2007 contains the following:
 

In Part 2 of this article, the author considers the question to what extent the directly applicable EC law on non-discrimination, as interpreted and enforced by the Community Courts, should be understood as a most-favoured-nation treatment obligation and, if so, how this would affect tax treaties.

With regard to the judgment in Portugal v. Commission, the author considers the Commission's interpretation of the criteria of geographical or regional selectivity, analyses the hypothesis and the conditions established, under which the general or selective character of the tax incentives for firms operating or with a domicile in certain geographical zones of a Member State may be understood and, finally, expresses doubts regarding parts of the judgment and considers the possible implications for Spain.

The author describes the reform of the German Reorganization Tax Act. In particular, he considers the extension of territorial scope in respect of foreign entities and reorganizations and privileged restructuring operations relating to mergers, divisions and changes of legal form, and reorganizations of transparent entities and singular succession asset transfers. The author also reflects on related changes regarding exit taxes and the transfer of the registered office or place of management.

This article provides an analysis of selected provisions of the new Belgium-US Income Tax Treaty. Specifically, the authors consider, with regard to corporate taxation, the treatment of fiscally transparent entities, dual resident companies, investment income, limitation on benefits, double taxation relief, and the mutual agreement and arbitration procedures.

In this note, the author considers the new Swedish rules on cross-border reorganizations introduced as a result of Directive 2005/19/EC. The changes apply from 1 January 2007.

In this note, the author examines the implications of the recent decision of the UK Special Commissioners in the Gaines-Cooper case in relation to what constitutes a day of tax presence in the United Kingdom with regard to the meaning of residence, ordinary residence and domicile.