June 2017  
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Issue No. 6 - 2017 of the European Taxation is now available online.

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Number 6 - 2017 contains the following:

The Tax Aspects of the Discussions Surrounding “Cum/Ex Trades”

Petra Eckl

The author provides an overview of the tax background to the discussion in Germany regarding structures related to trades made around the dividend record date.


Taxation of Technical Services under the new Article 12A of the UN Model – Improved Taxation or a Step in the Wrong Direction?

Franziska Sixdorf and Sebastian Leitsch

In this article, the authors examine the new article 12A of the UN Model (2017), which addresses technical services. The goals of the UN Model, as well as the objectives pursued by the UN Committee with the introduction of this new provision are presented, followed by an analysis of whether the new article meets these objectives.

Oana Popa
Oana Popa
Court of Justice
Oana Popa

Greek Council of State Decision on the Relationship between Tax Treaties and Domestic Legislation (Case No. 1445/2016)

Loukas Panetsos

In this note, the author comments on the decision of the Greek Council of State in Case No. 1445/2016, wherein the majority determined that the relevant tax treaty was not applicable since no juridical double taxation arose under domestic law.


Is a Board Secretary Included Within the Scope of Article 16 of the OECD Model (2014)?

Andy Cools

The author, in this note, discusses the past and current role of board secretaries and analyses whether or not this position is included within the scope of article 16 of the OECD Model (2014).

Finance Act 2016
Tom Maguire

Ireland’s most recent Finance Act was signed into law on 25 December 2016. It is a concise act, but with significant changes, the most noteworthy of which are discussed in this note.


The Notions of “Beneficial Ownership” and “Place of Effective Management” in Respect of a Passive Holding Company

Giorgio Beretta

In this note, the author considers a decision of the Italian Supreme Court on “beneficial ownership” and “place of effective management” for tax treaty purposes, wherein it was held that the meaning of these terms is to be determined in light of the nature and object of a financial holding company and that, therefore, a lack of substantial economic activity does not mean per se that such a company cannot be effectively established in the other contracting state.


New Transfer Pricing Guidelines on Intra-Group Financing Activities

Jean Schaffner and Sophie Balliet

The authors, in this note, describe the new circular on the tax treatment of companies carrying out intra-group financing activities, which was released by the Luxembourg tax authorities on 27 December 2016 and is effective 1 January 2017.


New Tax Administration Regime in Poland

Katarzyna Bronżewska

On 1 March 2017, the new Act on National Fiscal Administration entered into force in Poland, which completely overhauls the tax administration. The author, in this note, provides a summary of the previous regime, as well as the most significant changes stemming from the new law.

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