December 2018  
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Issue No. 12 - 2018 of the European Taxation is now available online.

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Number 12 - 2018 contains the following:
International/European Union

A Multi-Level Approach to “Treaty Entitlement” under the BEPS Project

Carlo Garbarino

This article analyses the three policy approaches to tax treaty entitlement that can be drawn from the new provisions introduced into the OECD Model (2017): the structural approach, the analytic approach and the syncretic approach. The article specifically describes the OECD Model and Commentary (2017). The analysis reveals important aspects of the impact of BEPS on tax treaties, notably that there are new limitations on treaty entitlement in addition to a general ban on double treaty exemption.

China (People's Rep.)/France/Korea (Rep.)

Taxpayer Fair Trial Rights and BEPS Implementation from the Perspectives of China, France and Korea

Youjin Jung

In this article, the author provides a comparative overview of the protection of taxpayer rights in France, Korea and China.

Mery Alvarado
Mery Alvarado
Mery Alvarado

Opinion Statement FC 7/2018 on a Proposal for a Council Directive Amending Directive 2006/112/EC, as Regards the Introduction of Detailed Technical Measures for the Operation of the Definitive VAT System for the Taxation of Trade between Member States (2018/0164(CNS))

CFE Fiscal Committee

This CFE Opinion Statement concerns the EU proposal to amend the VAT Directive to introduce detailed technical measures for the operation of the proposed definitive VAT system. In this Statement, the CFE sets out its concerns regarding the practical implications of introducing “Certified Taxable Persons” and the potential impact of the proposed Directive on SMEs, call-off stock and chain transactions, reverse charge supplies and the special schemes extending the one-stop account for VAT.


New Perspective on the Taxation of CFCs in Third Countries?

Lars F. Nielsen

This article examines the case of X-GmbH v. Finanzamt Stuttgart-Körperschaften (Case C-135/17). For this purpose, it provides a short overview of the relevant German CFC legislation. Subsequently, it examines Advocate General Mengozzi’s Opinion and discusses his conclusions in light of the EU Anti-Tax Avoidance Directive (2016/1164). It concludes that the ECJ’s decision might have consequences for the interpretation of articles 7 and 8 in third-country situations.


The Relationship between the EU Parent-Subsidiary Directive (2011/96) and Tax Treaties under Italian Case Law: Is Double Non-Taxation Always Undesirable?

Francesco Capitta

In this note, the author examines the decision of the Italian Supreme Court of Cassation in Case No. 23367/2017, given on 6 October 2017, regarding the application of a tax treaty provision to dividends received by a foreign parent company benefiting from the provisions of the EU Parent-Subsidiary Directive (2011/96) and considers the implications of double non-taxation.

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