10 October 2018  
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Issue No. 10 - 2018 of the European Taxation is now available online.

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Number 10 - 2018 contains the following:

European Union/United States

Unravelling the Recent US Tax Reform: A Paradigm Shift in the International and EU Tax Landscape

Hannelore Niesten

The aim of this contribution is to outline some of the implications and the possible spillover effect of key international tax features of the historic US tax reform from an EU perspective.

European Union

Pan-European Personal Pension Products – Will the Proposed European Tax Recommendation Work?

Sebastiaan Niels Hooghiemstra

This article discusses the effectiveness of the PEPP Tax Recommendation and the accompanying PEPP “portability service”. It provides an overview of certain anticipated problems in relation to the future taxation of PEPPs in Europe that led to this initiative, followed by an analysis of the effectiveness of the Recommendation and PEPP “portability service” in eradicating such problems. Finally, it reviews options for an alternative EU-wide PEPP tax regime.

European Union

Shaping Input Tax Incentives for Companies Spending on R&D under the 2016 CCTB Directive Proposal

Begoña Pérez Bernabeu

In this article, the author examines R&D incentives under the 2016 CCTB Directive Proposal.


Mery Alvarado


Mery Alvarado



Opinion Statement ECJ-TF 2/2018 on the ECJ decision of 7 September 2017 in Eqiom (Case C-6/16), Concerning the Compatibility of the French Anti-Abuse Rule Regarding Outbound Dividends with the EU Parent-Subsidiary Directive (2011/96) and the Fundamental Freedoms

CFE ECJ Task Force

This CFE Opinion Statement, submitted to the European Institutions in May 2018, addresses the ECJ’s decision in Eqiom (Case C-6/16), which concerns the EU law compatibility of the French anti-abuse rule regarding outbound dividends.

European Union

VAT Regime – Triangular Intra-Community Operations and Recent ECJ Case Law

Maruša Pozvek

This note discusses the VAT simplification measure, which is intended to reduce the administrative and compliance burden on traders and tax authorities with regard to registration and accounting, provided the three traders involved in the transaction are all VAT registrants in the European Union. In particular, the author comments on the ECJ decision in Firma Hans Bühler KG v. Finanzamt Graz-Stadt (Case C-580/16) and a recent proposal to amend the VAT Directive (2006/122).


The Tax Treatment of the Income of Internationally Active Football Referees under German Law: A Commentary on the German Federal Fiscal Court Decision in IR 98/15

Agnieszka Kopec and Filip Schade

This article analyses a decision of the German Federal Fiscal Court on the taxation of football referees. The authors describe the relevant statements of the Court and examine the possibility of an analogous application of the decision to other sports. As the decision relates to an outbound case (from a German perspective), the authors address whether or not it could apply to inbound refereeing activities.