April 2016

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European Taxation
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Issue No. 4 - 2016 of the European Taxation is now available online.

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Number 4 - 2016 contains the following:
European Union

Tax Rulings: In Line with OECD Transfer Pricing Guidelines, but Contrary to EU State Aid Rules?

Anja Taferner and Jurjan Wouda Kuipers

This article examines the Commission’s State aid investigations into certain tax rulings that are alleged to provide selective advantages to particular MNCs. It analyses the Commission’s views on how transfer pricing should have been applied in the recent cases, comparing this approach with the OECD Transfer Pricing Guidelines and the transfer pricing aspects of the OECD’s Base Erosion and Profit Shifting (BEPS) project.


Current Developments in the Corporate Taxation of Free-Float Shares – Can Participation Exemption Shopping Offer a Way Out?

Karl Broemel

In this article, the author introduces the concept of participation exemption shopping and analyses its potential advantages and disadvantages from a German and international tax perspective.


The New Italian Cooperative Compliance Regime

Mauro Manca

The author, in this article, discusses Legislative Decree no. 128 of 5 August 2015, which introduces into the Italian domestic tax system the new cooperative compliance regime as of 1 January 2016.

EU Update
Oana Popa
Oana Popa
Court of Justice
Oana Popa

Corporate Income Tax Act Changes

Lubka Tzenova

This note summarizes recent amendments to the Bulgarian Corporate Income Tax Act (CITA) that entered into force on 1 January 2016 and that are aimed at harmonizing domestic tax legislation with EU directives in the area of direct taxation and EU State aid rules.

European Union/International

Dispute Resolution in Cross-Border Tax Matters

Harm J. Oortwijn

The author, in this note, looks at the history and present trends of cross-border tax dispute resolution as discussed at the 20 November 2015 ICT Leiden Conference. The author provides his personal insights and comments, exploring the current state and future initiatives aimed at making dispute resolution more effective.


French Branch of Foreign Company Must Charge Interest to Its Head Office in Consideration for Cash Advances Provided to the Latter

Pierre Escaut and Guillaume Glon

This note examines a ground-breaking decision of the French Supreme Administrative Court that held that a French branch of a foreign company must, under transfer pricing rules, charge interest to its foreign head office in relation to internal cash advances provided to the latter despite the absence of a separate legal personality.


Recent Developments in German Tax Treaty Policy

Marisa Baltromejus

An overview of key changes pertaining to recent tax treaties and protocols signed by Germany is provided.