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   January 2019  
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European Taxation Journal Preview - January 2019
This free e-mail service informs you about the contents of the forthcoming edition of European Taxation.

Issue No. 1 - 2019 of the European Taxation is now available online.

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Number 1 - 2019 contains the following:

Belgium Finally Introduces Tax Consolidation as of 2019

Pieter Van Den Berghe and Sophie Verdonck

In this article, the authors discuss the features of the long-awaited tax consolidation regime introduced as part of a broader corporate tax reform effective 1 January 2019.


The Implications of the New German Investment Tax Regime on German and Non-German Fund Vehicles

Petra Eckl and Dominik Berka

This article provides an overview of the new tax regime for investment funds in Germany, which has been in effect since 1 January 2018.


Comparing Similar Enterprises under Article 24(5) of the OECD Model: Non-Discrimination and MFN Treatment in the Context of the Netherlands Group Taxation Regime

Recep Bagci

The author discusses the application of the ownership provision in article 24(5) of the OECD Model (2017) in the context of group taxation regimes. Taking the Netherlands group taxation regime as a base case, the author challenges the often applied limited comparison and argues that the ownership provision should allow Netherlands companies held by third-state resident companies similar consolidation possibilities as Netherlands companies held by EU Member State resident companies.

Mery Alvarado
Mery Alvarado
European Union

The Ulaanbaatar Declaration: 10 Key Priorities in International Taxation Identified by the Global Tax Advisers’ Platform (GTAP)

Piergiorgio Valente

The tax arena is undergoing significant change driven by globalization and digitalization, and a new global tax jurisdiction is emerging. Multiple international initiatives have been launched to identify proper norms for this new context, including the EU Platform for Tax Good Governance. Against this background, the Global Tax Advisers Platform (GTAP) was initiated by tax advisers from across the globe. The GTAP’s 10 Key Priorities were set out in the “Ulaanbaatar Declaration” signed on 12 September 2018.


Tax Shelter for Scale-Ups

Olivier Lambillon and Frank Hoogendijk

In this note, the authors outline the conditions for qualifying for the new tax shelter for scale-ups.


Germany’s Anti-Treaty/Directive-Shopping Provision Following the ECJ’s Decision in GS (Case C-440/17)

Sebastian Leidel and Konstantin Sakuth

The authors, in this note, examine the recent decision of the ECJ in GS (Case C-440/17), which addresses the German anti-treaty/directive-shopping provision applicable since 2012, including a discussion of the implications of the decision in practice and possible reactions of the German legislator.


Recent Legislation on the Tax Regime Applicable to “Carried Interest”

Stefano Serbini

This contribution describes article 60 of Law Decree No. 50 of 24 April 2017, which clarifies the regime applicable to “carried interest” compensation granted to managers and/or employees.

Slovak Republic

Amendments to the Dividend Taxation Regime

Zuzana Blažejová

In this note, the author discusses an amendment to the Slovak Income Tax Act introducing changes effective 1 January 2017 regarding the taxation of profit shares and other types of income connected to investments of both corporate and individual shareholders.

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