July 2015  
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Issue No. 7 - 2015 of the European Taxation is now available online.

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Number 7 - 2015 contains the following:
European Union
The End of Intra-Group Financing ... or Not Just Yet? – Part 1
Pascal Janssens, David Ledure, Bertrand Vandepitte and Jelle Loos
This article examines, first, how the outcome of the OECD BEPS Project will impact numerous aspects of intra-group financing as multinationals currently know it, serving as a roadmap for the reader to navigate through the jungle of rules considered and proposed by the OECD. At the same time, the authors are critical of
the OECD’ s proposals and analyse the extent to which they might result in collateral damage for the funding
of group or business investment in general. Part 1 addresses the borrower’ s perspective, while Part 2, to be
published in European Taxation 8 (2015), analyses the lender’ s perspective.
Implementation of the AIFM Directive in Italy – Overview of the Tax Implications
Francesco Mantegazza and Andrea Brambilla
The authors provide an overview of the main tax implications of implementation in Italy of the AIFM Directive (2011/61) for asset managers, investment funds and their foreign investors. Implementation of the AIFM Directive has given the Italian legislator an opportunity to introduce a new category of undertakings for
collective investment, defined as Italian fixed capital investment companies (SICAFs).
Contemporary Transfer Pricing Case Law of the Finnish Supreme Administrative Court
Seppo Penttilä and Martti Nieminen
This article examines recent transfer pricing case law of the Supreme Administrative Court. It provides an
analysis of four key decisions given between 2010 and 2014 concerning intra-group financing, in particular the amount of arm’ s length interest (KHO 2010:73) and debt recharacterization (KHO 2014:119); valuation of shares (KHO 2014:33) and location savings (KHO 2013:36).
The Eighty Years’ War, the Spanish Tax Lease System and Other Netherlands/Spanish Sea and Field Battles
Dick van Sprundel
The author discusses State aid in the context of the Spanish Tax Lease regime; a similar Netherlands tax structure
that combined temporary random depreciation, a tonnage tax regime and what is referred to as the Netherlands
shipping CV; as well as the Spanish Tax Lease 2 (STL2), developed in response to Commission actions taken against the original regime.
Laura Ambagtsheer-Pakarinen
Court of Justice
Laura Ambagtsheer-Pakarinen
The German Silent Partnership
Marisa Lipp
The author, in this note, provides a general overview of the taxation of silent partnerships in Germany. As an
example of a hybrid financial instrument, silent partnerships reflect the traditional tax distinction between debt and equity. Their use can lead to double taxation or double non-taxation in a cross-border context and it is, therefore, necessary to examine them critically.
The New Luxembourg Tax Ruling Procedure
Patrick Mischo and Franz Kerger
This note addresses the new legal framework regarding tax ruling requests filed with the Luxembourg tax administration, which was adopted in December 2014.
United Kingdom
Finance Act 2015
Douglas Roxburgh
The Finance (No. 2) Bill 2014-15 was made law as the Finance Act 2015 on 26 March 2015. This note covers those
provisions of the Finance Act 2015 that are of most relevance and importance for tax practitioners and provides
section references for the remainder.