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   November 2016  
ET Preview IBFD, Your Portal to
Cross-Border Tax Expertise
European Taxation
This free e-mail service informs you about the contents of the forthcoming edition of European Taxation.

Issue No. 11 - 2016 of the European Taxation is now available online.

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Global VAT – Countries
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12 December 2016
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Number 11 - 2016 contains the following:
United Kingdom/European Union

“God Save the Brexit”: Tax Implications of Leave Vote

Laura Ambagtsheer-Pakarinen, Ricardo García Antón, Laura Mattes, João Félix Pinto Nogueira, Oana Popa and Ruxandra Vlasceanu

This article covers the tax implications that may arise as a consequence of the exit of the United Kingdom from the European Union, detailing both indirect and direct tax matters.

European Union

Anti-Tax Avoidance Directive (2016/1164): New EU Policy Horizons

Aloys Rigaut

This article discusses the genesis of the Anti-Tax Avoidance Directive (2016/1164), its scope and main provisions, as well as some perspectives on future policy making.

European Union

Commission Initiative To Improve Dispute Settlement Mechanisms within the European Union – The EU Arbitration Convention (90/436)

H.M. Pit

On 17 June 2015, the European Commission announced its action plan on a fair and efficient corporate tax system in the European Union, which includes plans to improve dispute resolution procedures within the European Union, particularly focusing on the EU Arbitration Convention (90/436). This article discusses and evaluates these plans in light of the functioning of the Convention, taking into account developments at the international level, such as within the OECD.

Oana Popa
Oana Popa
Oana Popa
Court of Justice
Oana Popa

Tax Regime Applicable to Capital Gains on Real Estate Derived by Non-Resident Individuals: Current Regime and Future Prospects

Aurélien Mallaret

Between 2011 and 2016, opposing positions taken by lawmakers and the administrative courts generated a great deal of confusion over the effective tax rate applicable to a sale of a property by an individual. This note provides an overview of the actual French capital gains tax regime for non-residents, as well as issues that have yet to be resolved in the relevant case law.


Leveraged Buy-Outs and Foreign Shareholder Loans: Issues Arising from the Recent Approach of the Italian Tax Authorities 

Stefano Morri and Stefano Guarino

The Italian tax authorities recently issued an analysis of leveraged buy-out transactions, noting the possibility of recharacterizing shareholder loan agreements as capital contributions by applying paragraph 1.65 of the OECD Transfer Pricing Guidelines, which allows tax authorities to recharacterize structures in accordance with their economic substance. This note questions whether the Italian tax authorities’ concept of “economic substance” is compliant with accounting and finance tenets and is still applicable in light of the OECD’s BEPS Actions 8-10.

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