May 2015  
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European Taxation
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Issue No. 5 of the European Taxation is now available online.

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Number 5 - 2015 contains the following:
The Tax Treatment of Shareholder Loans in Germany
Martin Weiss
This article describes the tax treatment of shareholder loan impairments under German tax law within the context of the German national participation exemption regime. In particular, the changes introduced by a recent amendment to the German Income Tax Act are highlighted. The article traces the historical development leading up to the legislative change and analyses the key features of the new provision.
United Kingdom
The New “Google Tax”: The “Beginning of the End” for Tax Residence as a Connecting Factor for Tax
Luca Cerioni
The author, in this article, analyses the recently announced UK diverted profit tax and the potential issues that may arise in connection with its introduction, comparing it to the destination-based corporate tax that is increasingly being proposed in the literature.
Citizenship and Taxation in France
Andreas Kallergis
This article discusses the Andorra-France Income Tax Treaty (2013), which includes a specific clause to tackle the effects of “tax exile”, potentially paving the way for citizen-based taxation in the future.
European Union
The Taxation of Social Enterprise
Anuschka J. Bakker
This article looks at the nature of social enterprise, the problems encountered in this area, as well as the tax
incentives available in various European countries.
Laura Ambagtsheer-Pakarinen
Court of Justice
Laura Ambagtsheer-Pakarinen
Joint AOTCA/CFE Opinion Statement FC 1/2015 on the OECD 2014 Public Discussion Draft on Preventing
the Artificial Avoidance of PE Status (BEPS Action 7)
CFE Fiscal Committee
Prepared by the CFE Fiscal Committee and agreed with AOTCA, submitted to the OECD in January 2015.
European Union/International
Tax Transparency – How To Make It Work
Rudolf Reibel
The author reports on the 7th CFE Professional Affairs Conference held on 5 December 2014 in Paris, wherein
three aspects of tax transparency were discussed: corporate country-by-country reporting (CBCR), mandatory disclosure of tax avoidance schemes and “cooperative compliance” in respect of the relationship between taxpayers and their advisers and the tax administration.
New Preferential Intellectual Property Regime
Giulia Gallo and Stefano Balestieri
This note summarizes the recently enacted Italian preferential intellectual property (IP) regime that has been in effect since 1 January 2015.
Clarification of the Tax Treatment of Limited Partnerships
Patrick Mischo and Paul Berna
The Luxembourg tax administration issued a circular on 9 January 2015 clarifying the direct tax treatment of Luxembourg limited partnerships. This note comments on the impact of the circular on the alternative
investment fund sector.
Income Tax Amendments in Poland: New Thin Cap Rules Effective 1 January 2015
Agnieszka Kopec and
Marcin Jamroży
This note discusses the new Polish thin capitalization rules. The authors critically analyse the tax changes and
highlight the practical limitations and possible implications of the new legal regulations on the tax deductibility
of interest.