EU Tax Law Study Group

The EU Tax Law Study Group is a think tank dedicated to the study of tax law developments in the European Union, specifically related to direct taxation.

About us

Housed within IBFD’s European Knowledge Group, it is staffed by a team of specialists in EU tax law – direct taxation and supported by specialists in other EU topics of interest, including indirect taxation and transfer pricing.

The primary task of the EU Tax Law Study Group is to remain abreast of the evolving EU developments, and to ensure swift responses to these developments. The group's activities include: 

  • conducting and facilitating research activities in the area of EU direct tax law
  • publishing articles, white papers, and statements on current EU tax law initiatives
  • monitoring, analysing and reporting on EU tax developments; and
  • contributing to expanding and strengthening of the product and service portfolio of IBFD.

EU Tax Focus Notes

This section provides updates on the progress in ongoing EU direct tax initiatives. Its objective is to serve as a specialized source, providing insights into the initiatives and uncovering their possible consequences. Additionally, it includes concise expert perspectives on the (implications of) other EU tax developments.

Scroll the EU Tax Focus notes below to stay updated on EU Tax developments and benefit from the perspective of our thought leaders.

 

The New US Administration Has the European Union Navigating Between Scylla of Pillar 2 and Charybdis of US Retaliation

Author: Dominick Schirripa

Update created: 19 May 2025

In January 2025, President Donald Trump issued a presidential memorandum declaring that commitments made by the Biden Administration in the context of the OECD’s two-pillar solution had no continued force in the United States. While the memo did not withdraw the United States from the OECD or even the Inclusive Framework’s continued discussions, it did send a clear signal that the new US Administration has little, if any, interest in the contents of the deal or in seeing it incorporated into US law. This note provides an overview of the status quo both at EU and US level and looks into the US position going forward in the aftermath of Mr. Trump’s announcement.

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Direct tax considerations of a potential EU Australia free trade agreement

Author: Marwan Ahmed

Update created: 16 May 2025

Undeniably, in 2025, international trade has been shaken by the tariffs imposed by the United States despite its existing trade agreements with other countries. This situation may, however, present unique opportunities for trade among countries which do not currently operate by means of a free trade agreement. This note builds on the prospect of an EU-Australia free trade agreement and explores its potential direct tax considerations.

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Towards a Simpler and More Efficient EU Anti Tax Avoidance Framework: Key Priorities for Future Reform

Author: Francesco De Lillo

Update created: 15 May 2025

On 15 May 2022, the European Parliament’s FISC Subcommittee held a public hearing on “The Future of EU Anti-Avoidance Tax Rules, Including Simplification”. This policy note builds upon the statement delivered by the author in representation of the IBFD. It begins by outlining the EU policy objectives that underpin a revision of the EU’s current anti-tax avoidance framework. Then, it examines selected design challenges within the existing anti-abuse rules, as well as broader issues contributing to regulatory complexity in the Single Market. Finally, it identifies a set of guiding principles to inform future reform efforts.

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The substance game: Interpretation of anti-abuse rule contained in Parent-Subsidiary Directive

Author: Filip Krajcuska

Update created: 14 April 2025

On 3 April 2025, the Court of Justice of the European Union (ECJ) issued its decision in Nordcurrent group (Case C-228/24), following the request for a preliminary ruling by a Tax Disputes Commission under the Government of the Republic of Lithuania. In the decision, the ECJ sheds light on the interpretation of the anti-abuse rule contained in the Parent-Subsidiary Directive (2011/96). This note provides a taster of the decision. 

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The US-EU Tariff War: From Cooperation to Confrontation

Author: Katerina Ilieva

Update created: 10 April 2025

This note examines President Trump’s 2025 tariffs on imports from the EU and the Union’s retaliatory response, highlighting the mechanics of tariffs and their impact on businesses and consumers. It also outlines the evolving trade dynamics, the EU’s strategic response, and the broader implications for transatlantic relations and the global economy.

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Tax Transparency: A Win-Win Situation in the Quest for Tax Justice?

Authors: Tomás Costa Ramos and Carlota Mendes Martins

Update created: 10 April 2025

Over the past decade, the international policy framework has been witnessing global advocacy for tax transparency, with regulatory initiatives aiming to ensure responsible tax practices and to hold multinational enterprises (MNEs) accountable for paying their fair share of taxes. This note explores the foundations of tax transparency, its role in combating tax avoidance, and the benefits for both stakeholders and MNEs in disclosing tax-related information. 
 

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Legality of the solidarity contribution under international law – Klesch Group & Raffinerie Heide v. Germany

Author: Ola Ostaszewska

Update created: 28 March 2025

This note discusses a case at the International Centre for Settlement of Investment Disputes (ICSID), in which the legality of the solidarity contribution imposed by Germany has been challenged under the Energy Charter Treaty (ECT). It also highlights possible implications of this case for other investors established in countries that are parties to ECT.

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EU Tax Law and Policy of Tomorrow: Insights from the 2025 EU Tax Symposium

Author: Oana Popa, Carla Valério & Angelika Xygka

Update created: 18 March 2025

Discussions around the European Union tax agenda for 2024-2029, influenced by US developments and the negotiations for the UN Framework Convention, have grown more complex. The 2025 EU Tax Symposium served as the platform for the evolving tax conversation to unfold, and this note delves into its most relevant discussions and insights.

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Negotiating the UN Framework Convention – what next for the European Union?

Author: Belema Obuoforibo CTA ATT (Fellow)

Update created: 15 March 2025

This note addresses the European Union’s approach to the current UN process for negotiating the UN Tax Framework Convention, and, in particular, how the European Union has responded to two of its key requests not having been fully met. Although the European Union has professed its support for the work at the UN, will it finally run out of patience and follow the United States out the door?

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Future Taxation of Robots: An EU Perspective

Author: Stoycho Dulevski & Katerina Ilieva

Update created: 10 February 2025

The rapid advancement of robotics and artificial intelligence has sparked global discussions about their economic and social implications, particularly their impact on the labour market and tax systems. One key debate is whether considering the current technological revolution and in response to the abovementioned economic shift, taxation on robots should be implemented and, if so, how it should be structured. This note examines whether robots could be classified as taxable persons under EU law from a direct and indirect tax perspective and explores potential future tax frameworks for robotics.

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Transfer Pricing Documentation in the EU: Courtroom Battles and Tax Authorities’ Scrutiny

Author: Anca Aron

Update created: 30 January 2025

Transfer pricing documentation has been a focal point of disputes between multinational enterprises and tax authorities across the European Union. This note outlines the key landmark cases and major challenges tax authorities and MNEs face in the European Union regarding TP documentation. It explores how courts interpret compliance requirements, evidentiary standards and the consequences of inadequate TP documentation. Additionally, it examines the increasing scrutiny by tax authorities, particularly regarding the application of the arm’s length principle and the role of the OECD TP Guidelines in dealing with TP documentation. 

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Recent EU Direct Tax Initiatives: The End of Tax Sovereignty?

Author: João Carmona Lobita and Francisco Loureiro Ferreira

Update created: 10 January 2025

The term “tax sovereignty” commonly refers to a state’s authority to independently design and enforce its tax laws. Due to its importance as a revenue source and tool of economic policy, taxation is considered a core element of a state’s sovereignty. Despite states naturally resisting any external interference with their taxes, the recent Minimum Taxation Directive and the BEFIT proposal at EU level raise important questions in that regard. This note discusses the general framework for tax within the European Union and how recent initiatives tie with tax sovereignty.

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Artificial Intelligence Usage in EU Tax Administrations 

Author: Katerina Ilieva

Update created: 10 January 2025

Artificial Intelligence (AI) is widely used in the taxation field as a tool for supporting taxpayer compliance and reducing taxpayer burden. It also benefits tax administrations by streamlining internal processes, reviews, audits and decision-making, leading to a more efficient use of resources. This note gives a brief overview of how EU tax administrations are leveraging AI and presents some examples of Member States that are successfully using AI – to enhance tax-related services, ensure tax compliance and more.

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Public country-by-country reporting: Tax transparency and allocation of group profits  

Author: Ivana van der Maas

Update created: 10 January 2025

In the global economy, tax transparency has emerged as a basis of responsible corporate governance. MNEs play a significant role in the economies of the jurisdictions in which they operate. However, concerns about potential tax avoidance and profit shifting have placed these companies under the spotlight. As a result, governments, regulatory bodies and stakeholders are calling for greater accountability in how these corporations allocate their profits and pay taxes. This note explores how the introduction of public country-by-country reporting (CbCR) requirements in the European Union is a significant step in addressing said concerns.

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Legal Professional Privilege under DAC6 in the Wake of Recent ECJ Judgements

Author: R. Vlasceanu

Update created: 23 December 2024

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Corporate Sustainability Reporting Directive: What's in It for Tax?

Author: F. De Lillo

Update created: 20 December 2024

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Does Gabel Industria Tessile and Canavesi (C-316/22) demand the application of the EU principle of effectiveness to Portuguese road network user charge disputes brought by final consumers?

Author: S. Fernandes Martins

Update created: 4 December 2024

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Approval of ViDA legislative package. What is next?  

Author: Laura Alarcón Diaz

Update created: 20 November 2024

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EU FASTER Proposal: Are we moving towards more efficient withholding tax procedures within the European Union? 

Author: Angelika Xygka

Update created: 14 November 2024

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Compatibility with EU Law of Tax Benefits Available Solely for Construction Sector Employees Operating Locally  

Author: Katerina Pantazatou

Update created: 11 November 2024

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The Latest Proposed Amendment to DAC: A Short Introduction of DAC9

Author: Katerina Ilieva

Update created: 1 November 2024

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On Tax Harmonization, Fairness and Beyond – Perspectives of a Member of the European Parliament

Interviewee: Bruno Gonçalves, MEP

Update created: 15 October 2024

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Pillar Two but make it Greek: Law 5100/2024

Authors: Maxine Avlihou and Timoleon Angelos Christodoulopoulos

Update created: 30 September 2024

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The ECJ Final Decision in Apple – A Key Milestone in the EU Fight against Tax Avoidance

Update created: 15 September 2024

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OECD Pillar One Reform and the European Union: Do good things come to those who wait?

Update created: 6 September 2024

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Gulliver’s Tax Travels: Discovering Special Tax Regimes for Inward Expatriates in 2024

Update created: 4 September 2024

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Hopefully We Will Say Goodbye to the Unshell Proposal

Update created: 2 August 2024

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The Elephant in the Room: A Minimum Tax on Billionaires

Update created: 2 August 2024

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“The only constant in life is change” … So, should VAT become progressive?

Update created: 15 July 2024

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What to expect in terms of EU tax law and policy from the second half of 2024 (and beyond)

Update created: 8 July 2024

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The “lost but not found” initiatives’ club: Unshell and others

Update created: 24 June 2024

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A Framework for Taxation of Telework Income in the European Union: How Late?

Update created: 18 June 2024

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FASTER, but softer: How the Council lowered the standards to make a quick match

Update created: 29 May 2024

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Fugro v. Council: The story of a taxpayer “throwing down the glove” at the Minimum Taxation Directive

Update created: 28 May 2024

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Through Thick and Thin: BEFIT under Scrutiny

Update created: 25 April 2024

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Brief Overview of the ECJ Advocate General’s Opinion in the UK CFC Group Financing Exemption and a Trip Down Memory Lane, Revisiting Analogous State Aid Cases

Update created: 16 April 2024

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Tax Simplification 101: HOT is Moving Forward

Update created: 15 April 2024

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Can FASTER come any faster (pun intended)?

Update created: 12 March 2024

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Let me brief you on DAC8: Key contextualized topics on crypto and beyond

Update created: 11 March 2024

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Fitting the puzzle pieces in the latest update of the EU list of non-cooperative jurisdictions for tax purposes

Update created: 21 February 2024

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Meet our team

 

Ola Ostaszewska

Ola Ostaszewska

Manager, European Knowledge Group

Ruxanda Vlasceanu

Ruxanda Vlasceanu

Managing Principal Mergers & Acquisitions

Oana Popa

Oana Popa

Principal Associate

Angelika Xygka

Angelika Xygka

Associate

Laura Pakarinen

Laura Pakarinen

Principal Associate

Carla Valerio

Carla Valério

Associate