January 2015  
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Issue No. 1 - 2015 of the European Taxation is now available online.

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Number 1 - 2015 contains the following:

European Union

Blueprint for a New Common Corporate Tax Base

Jaap Bellingwout

In response to the shortcomings of the corporate tax systems of the Western world, the OECD has initiated its Base Erosion and Profit Shifting initiative. Similarly, actions have been endorsed by the European Commission in its fight against aggressive tax planning. The author, in this article, takes a different approach to the issue by examining alternative concepts of a harmonized tax base with respect to routine profits and centralized taxation of residual profits within the European Union.
European Union
The OECD Intangibles Project and the Concept of “Intangible Related Return”

Carlo Garbarino and Mario D’Avossa

This article examines the OECD’s recent work regarding certain transfer pricing aspects of intangibles as reflected in BEPS Action Plan No. 8. In particular, the authors provide a description of the project, as well as the activities undertaken by Working Party No. 6 up to March 2014, describe the interim work performed by Working Party No. 6 in connection with the attribution of the “Intangible Related Return” to members of a multinational group and address comments on the “Intangible Related Return” concept received by Working Party No. 6 from business commentators.
European Union
Taxation of Cross-Border Supplementary Pensions: Still an Obstacle to the Free Movement of Workers in the European Union?
Clara Maria Grassi
The author, in this article, discusses the taxation of cross-border supplementary pensions in relation to article 45 of the Treaty on the Functioning of the European Union. The article addresses the current state of the law and what remains to be done (if anything) to ensure that the taxation of cross-border pensions will not represent an obstacle to the free movement of workers in the European Union.
Laura Ambagtsheer-Pakarinen
Laura Ambagtsheer-Pakarinen
Court of Justice
Laura Ambagtsheer-Pakarinen
Opinion Statement FC 14/2014 on the VAT Treatment of Vouchers

Prepared by the CFE Fiscal Committee and Submitted to the European Commission and the EU Council in September 2014

Legislation Requires Withholding Tax To Be Paid on Certain Payments to Branches Established in Greece but Not Payments between Greek Companies
Katarina Perrou
A new Income Tax Code was introduced in Greece effective 1 January 2014, article 62 of which identifies payments that are subject to withholding tax. This note describes the provisions and demonstrates that, in certain respects, they are incompatible with both the EU fundamental freedoms and the non-discrimination provisions of tax treaties.
Government Presses Ahead with Controversial Sectoral Taxation Policy through the Introduction of an Advertisement Tax
Roland Felkai
This note addresses the new advertising tax that was introduced with effect from 15 August 2014 in continuation of a long-term government commitment to a series of sectoral special taxes. In this context, Hungary has already faced criticism, including by the ECJ. This new tax applies not only to companies providing advertising services, but also – via a kind of reverse charge procedure - to absorbing companies, including foreign-based companies.
2014 Income Tax Law Changes: New Taxation Rules for Partnerships Limited by Shares
Stephan Kudert, Agnieszka Kopec and Agata Nagel
In this note, the authors discuss the new tax regulations for Polish partnerships limited by shares, which were introduced effective 1 January 2014 pursuant to amendments to the Polish Corporate and Personal Income Tax Acts.