July 2016  
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Issue No. 7 - 2016 of the European Taxation is now available online.

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Other publications and courses available on Europe:

[Conference]
International Taxation Conference 2016
1-3 December 2016

Mumbai
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[Course]
European Value Added Tax - Selected Issues
16-18 November 2016
Amsterdam

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Number 7 - 2016 contains the following:
ARTICLES
International

Beneficial Ownership: Concept, History and Perspective

Caroline Poiret

This article traces the evolution of the beneficial ownership concept, both internationally and within the European Union, in the context of two decisions of the Swiss Supreme Court handed down in May 2015, wherein it was held that two Danish banks, involved in derivative transactions, should be denied a withholding tax refund, as they are not the beneficial owners.

Greece

What’s Wrong with the Greek General Anti-Avoidance Rule?

Konstantinos Petoumenos

During the financial crisis, Greece introduced a series of tax reforms aimed at improving public revenue through tax increases, combatting tax evasion and eliminating tax avoidance. This article examines the Greek general anti-avoidance rule and highlights the controversies arising from its regulatory basis.

Portugal

The Deduction of Corporate Costs in Portugal: Recent Developments

António Martins

In 2014, the general principle regarding the deduction of corporate costs under the Corporate Income Tax Code was changed. The requirement that a cost be indispensable in generating revenue was abandoned in favour of a new provision pursuant to which costs have to be incurred in order to obtain or secure income. This article explores how the tax authorities, taxpayers and courts can interpret this change, as well as recent international trends regarding this core issue of corporate taxation.

EU UPDATE
Commission
Oana Popa
Parliament
Oana Popa
Parliament and Council
Oana Popa
Court of Justice
Oana Popa
WHAT'S GOING ON IN ...
Germany

The Proposed Draft of the Investment Tax Reform Act

Petra Eckl

This note provides an overview of the proposed new tax regime for investment funds under the Draft Investment Tax Reform Act.

Germany

Constitutionality of Treaty Override

Adrian Cloer and Tobias Hagemann

This note discusses a recent decision of the Federal Constitutional Court, wherein it was held that treaty override is constitutional.

Italy

Italian Supreme Court Holds that CFC Rules Are Compatible with EU Law and Tax Treaties

Francesco Avella and Valentina Mollica

In this note, the authors discuss the decision of the Italian Supreme Court in Case no. 25281, wherein it was held that the Italian CFC rules are consistent with EU law and with tax treaties patterned after the OECD Model.

OFFICIAL JOURNAL OF THE CONFÉDÉRATION FISCALE EUROPÉENNE