January 2016  
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European Taxation
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Number 1 - 2016 contains the following:
Interest Deduction Limitations: When To Apply Articles 9 and 24(4) of the OECD Model
Otto Marres
This article discusses the application of articles 9 and 24(4) of the OECD Model to interest deduction limitations. The article then compares the solution in the OECD Model to the ECJ’s approach to the issue of whether discriminatory transfer pricing and thin capitalization provisions are contrary to the fundamental freedoms of the Treaty on the Functioning of the European Union (2007).
Compartmentalization in the Netherlands Participation Exemption: A Model for Europe?
Jeroen van Strien
This article discusses the concept of compartmentalization in the context of the Netherlands participation
exemption. The author outlines a decision of the Netherlands Supreme Court wherein it was held that a statutory base is needed for such compartmentalization to apply in the event of a change in legislation and then analyses remedial legislation enacted in response to the decision and its compatibility with EU law.
European Union
Automatic Exchange of Tax Information in the European Union – The Standard for the Future
Alicja Brodzka
This article analyses various perspectives regarding the future European standard for automatic exchange of tax information. It presents the legal framework for such information exchange within the European Union and discusses the influence of the US FATCA on the EU legal environment. Finally, it questions whether or not the
international tax information exchange system, based on automatic transfer of data, can work effectively and whether the obstacles caused by differences amongst Member States can be overcome.
Laura Ambagtsheer-Pakarinen
Laura Ambagtsheer-Pakarinen
Laura Ambagtsheer-Pakarinen
Opinion Statement ECJ-TF 1/2015 of the CFE on the Decisions of the European Court of Justice in Commission
v. Spain
(Case C-127/12) and Commission v. Germany (Case C-211/13) Concerning Inheritance Taxation
CFE ECJ Task Force
This is an Opinion Statement prepared by the CFE ECJ Task Force concerning two decisions given by the ECJ in September 2014 regarding the compatibility of inheritance taxation with the fundamental freedoms (Commission v. Spain (Case C-127/12) and Commission v. Germany (Case C-211/13)), submitted to the European Court of Justice, the European Commission and the EU Council in April 2015.
European Union/International
Taxation of the Digital Economy in Selected Countries – Early Echoes of BEPS and EU Initiatives
Oana Popa
This note highlights the initiatives of a number of countries to address taxation of the digital economy in response to the OECD’s BEPS Project and is based on information up to 1 October 2015.
New Provisions on a Transfer of Residence in an Inbound Scenario
Davide Alberto de Santis
This note addresses Legislative Decree No. 147 of 14 September 2015 with specific reference to the provisions
included in article 12 relating to a transfer of residence in an inbound scenario (i.e. a transfer of tax residence from a foreign country to Italy). In particular, this note focuses on the issues solved by the provision and on those scenarios that are still not covered.
Implementation of the Amendments to the Parent-Subsidiary Directive (2011/96) into Luxembourg Law
Patrick Mischo and Jacques Wantz
The authors, in this note, discuss Bill No. 6847, which, inter alia, transposes the latest amendments to the Parent-
Subsidiary Directive (2011/96) into the Luxembourg Income Tax Law.