If you have difficulty viewing this message please click here
  

January 2017

 
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. 1 - 2017 of the European Taxation is now available online.

Visit www.ibfd.org for more information about IBFD publications and services.

Archive | Subscribe to other Journal Previews

IBFD
P.O. Box 20237
1000 HE Amsterdam
The Netherlands
Tel: 31-20-554 0176
Fax: 31-20-622 8658
info@ibfd.org
www.ibfd.org
Unsubscribe

Conference
3rd IBFD Africa Tax Symposium
10-12 May 2017
Accra, Ghana
> Read more

Course
European Value Added Tax Masterclass
18-19 May 2017
Amsterdam
> Read more

You can also view this content on your mobile via m.ibfd.org.
 
Number 1 - 2017 contains the following:
ARTICLES
European Union

The Impact of ATAD on Domestic Systems: A Comparative Survey

Daniel Gutmann, Andreas Perdelwitz, Emmanuel Raingeard de la Blétière, René Offemanns, Marnix Schellekens, Giulia Gallo, Adrián Grant Hap and Magdalena Olejnicka

This article provides an analysis of the Anti-Tax Avoidance Directive (2016/1164) of 12 July 2016. Following a discussion of the Directive’s main features (the interest limitation, exit taxation, general anti-avoidance, CFC and hybrid mismatch rules), a survey is provided of the impact of the Directive on the tax systems of various Member States. It concludes with a comparative analysis and reflections on the manner in which the Directive will be transposed by the Member States.

Italy

Profits and Losses of Foreign Permanent Establishments: The Optional Branch Exemption Regime

Pietro Mastellone

The author, in this article, discusses article 14 of the Internationalization Decree, which allows taxpayers to opt for a branch exemption in respect of the profits and losses of a foreign permanent establishment as an exception to the credit method.

EU UPDATE
Commission
Laura Pakarinen
Council
Laura Pakarinen
Court of Justice
Laura Pakarinen
CFE NEWS

Opinion Statement ECJ-TF 2/2016 on the Decision of the Court of Justice of the European Union of 13 July 2016 in Brisal and KBC Finance Ireland (Case C-18/15), on the Admissibility of Gross Withholding Taxation of Interest

CFE ECJ Task Force
WHAT'S GOING ON IN ...
European Union/Netherlands

Real Estate Funds: VAT Exemption for Fund Management Services

Raphaël Glohr and Michel Lambion

The authors comment on the decision of the Court of Justice of the European Union in Fiscale Eenheid X NV (Case C-595/13), wherein the Court confirmed that real estate investment funds are eligible to receive VAT-exempt management services, but that “property management” services are not included in this concept, and establish a clear link between the benefit of the VAT exemption and the “specific state supervision”.

France

3% Corporate Income Tax Surcharge on Distributed Income: The Beginning of the End?

Aurélien Mallaret

Since its introduction in 2012, the future of the 3% corporate income tax surcharge on distributed income has become increasingly uncertain in light of certain case law. This note aims to provide an overview of the ongoing legal debate and of refund opportunities that require action before 31 December 2016.

Germany

Implementation of BEPS Initiative and EU Directive in Germany

Marisa Baltromejus

This note outlines the contents of the draft German bill implementing the recommendations of the OECD BEPS project Final Reports, as well as the EU Automatic Information Exchange Directive (2015/2376).

OFFICIAL JOURNAL OF THE CONFÉDÉRATION FISCALE EUROPÉENNE
Please consider the impact on the environment before printing this e-mail.