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   May 2016  
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European Taxation
This free e-mail service informs you about the contents of the forthcoming edition of European Taxation.

Issue No. 5 - 2016 of the European Taxation is now available online.

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Number 5 - 2016 contains the following:
European Union

EU Code of Conduct – From Reviewing Individual Tax Regimes to Developing Horizontal Policy: Cracking the Code in the BEPS Era

Vinod Kalloe

The author, in this article, chronicles the history of the work of the Council’s EU Code of Conduct Group, which was originally mandated to fight individual harmful tax practices but whose work has been gradually extended to developing coordinated horizontal tax policy to fight base erosion and profit shifting.


EU Commission Releases Draft Directive on BEPS: A Critical Analysis from a Luxembourg Perspective

Oliver R. Hoor, Keith O’Donnell and Samantha Schmitz-Merle

On 28 January 2016, the European Commission presented its Anti Tax Avoidance Package, one of the core pillars of which is a Draft EU Anti Tax Avoidance Directive or “Anti-BEPS” Directive. The Draft Directive proposes anti-tax avoidance rules in six specific areas, which are intended to be implemented by each EU Member State. This article provides an overview of the proposed provisions and analyses how they may impact Luxembourg tax law.


Recent Amendments to the German Tax Rules on Rollover Relief

Martin Weiss

This article describes recent amendments to the German rules on rollover relief enacted following a lengthy academic debate and the ECJ decision in Commission v. Germany (Case C-591/13). For certain assets held in a domestic permanent establishment, taxpayers can now spread the tax payment over a period of five years instead of paying tax immediately upon disposal if new assets attributable to a permanent establishment in the European Union or European Economic Area are acquired.


Implementation of the New Anti-Avoidance Provisions of the Parent-Subsidiary Directive (2011/96) into Swedish Law

David Kleist

In this article, the author outlines the implementation of the new anti-avoidance provisions of the Parent-Subsidiary Directive (2011/96) into Swedish law and raises the question of whether or not the minimalistic implementation strategy chosen by the Swedish legislator adequately complies with the requirements of the provisions.

Oana Popa
Oana Popa
Court of Justice
Oana Popa

Opinion Statement ECJ-TF 4/2015 on the Decision of the European Court of Justice in Groupe Steria SCA (Case C-386/14), on the French Intégration Fiscale

CFE ECJ Task Force
European Union

The New Era of EU Customs Legislation

Aleksandra Bal

In this note, the author highlights important aspects of the new Union Customs Code including, inter alia, the inclusion of royalties and licence fees in the customs value, the first-sale principle, customs procedures, the Binding Tariff Information, the authorized economic operator and the provision of guarantees.


Changes in the Internationalization Decree Regarding PEs of Non-Resident Entities and Possible Implications on Source Taxation of “Notional Income”

Mario De Blasi and Luca Bosco

This note discusses the changes included in Legislative Decree 147/2015 regarding measures for the growth and internationalization of enterprises. In particular, the focus is on article 7, which has changed the regulation of Italian PEs of non-resident entities by revising the principles for the determination of the tax base of non-resident taxpayers. Furthermore, the contribution addresses some tax issues, in terms of source-country taxation, regarding internal dealings between Italian PEs and parent companies.


New Anti-Avoidance Provisions in Poland – A Change of Scenery

Hanna Filipczyk

This note provides an overview of recent developments in respect of Polish tax law and practice targeting corporate tax avoidance.

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