April 2015  
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Issue No. 4 - 2015 of the European Taxation is now available online.

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Number 4 - 2015 contains the following:
ARTICLES
Luxembourg
Luxembourg Reshapes Its Transfer Pricing Landscape
Oliver R. Hoor
On 19 December 2014, the Luxembourg legislator adopted new transfer pricing legislation that formalizes the application of the arm’ s length principle and the requirement for specific transfer pricing documentation. While the arm’ s length principle was already firmly ingrained in Luxembourg tax law, the new rules further elevate the importance of transfer pricing. This article provides an overview of Luxembourg’ s new transfer pricing landscape.
European Union
Secondary Establishments in EU VAT and Treaty Law
Aleksandra Bal
This article compares the concept of secondary establishment for direct and indirect tax purposes, as defined
in the OECD Model (2014), the UN Model (2011) and the EU VAT Directive (2006/112). It also examines recent
developments regarding the interpretation of the fixed establishment concept by the ECJ and possible modifications to the permanent establishment concept stemming from current discussions on the taxation of the digital economy.
European Union/International
BEPS Impact on EU Law: Hybrid Payments and Abusive Tax Behaviour
Evgenia Kokolia and
Evgenia Chatziioakeimidou
The authors, in this article, analyse the OECD’ s deliverables from 16 September 2014 on Action 2, “Neutralising
the effects of Hybrid Mismatch Arrangements” and Action 6 on “Preventing the Granting of Treaty Benefits in
Inappropriate Circumstances”, as well as recently adopted relevant EU legislation. The authors consider whether targeted measures are necessary at the EU level to incorporate solutions proposed at the OECD level in order to tackle aggressive tax planning and corporate tax avoidance.
EU UPDATE
Commission
Laura Ambagtsheer-Pakarinen
Council
Laura Ambagtsheer-Pakarinen
Court of Justice
Laura Ambagtsheer-Pakarinen
CFE NEWS
Opinion Statement FC 15/2014 on Developing a Multilateral Instrument to Modify Bilateral Tax Treaties
(BEPS Action 15)
CFE Fiscal Committee
This is an Opinion Statement on Developing a Multilateral Instrument to Modify Bilateral Tax Treaties (BEPS Action 15), prepared by the CFE Fiscal Committee and submitted to the OECD in December 2014. Action 15 (a multilateral instrument to modify bilateral tax treaties): CFE Opinion Statement 15/2014 of 19 December.
WHAT'S GOING ON IN ...
Armenia
Has the Pension Reform in Armenia Solved the Existing Problems or Merely Created a New, Bigger One?
Mesrop Manukyan
This note critically examines the new compulsory retirement savings plan that has been in force in Armenia since
1 July 2014.
Belgium
Belgian Ruling Commission’ s Opinion on the Concept of “Employer” within the Meaning of Article 15 of the OECD Model
Andy Cools
The author discusses a recently published ruling of the Belgian Ruling Commission on a number of implementation measures contained in article 15 of the OECD Model (2010), in particular, whether substance
should prevail over form in defining the concept of “employer” for the purposes of article 15, as well as the “by or
on behalf of” criterion.
Bulgaria
Corporate Income Tax Act Changes
Lubka Tzenova
This note summarizes recent amendments to the Bulgarian Corporate Income Tax Act that became effective
1 January 2015, which were designed to harmonize Bulgarian tax legislation with the requirements of EU law.
Greece
New CFC Rules
Katerina Perrou
This note examines in detail the new CFC rules in article 66 of the Income Tax Code, which entered into force on 1 January 2014, including their compatibility with EU law.
OFFICIAL JOURNAL OF THE CONFÉDÉRATION FISCALE EUROPÉENNE