April 2019  
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Issue No. 4 - 2019 of the European Taxation is now available online.

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Number 4 - 2019 contains the following:
European Union

The Primacy of EU Law and the Retroactive Application of ECJ Case Law: The Spanish Application of ECJ Case Law on the Horizontal Tax Group

Enrique Sánchez de Castro Martín-Luengo

The principle of primacy of EU law plays an important role at the domestic level of the EU Member States. EU law must be directly applied not only by courts, but also by administrative bodies. This is particularly the case when there is settled ECJ case law on a particular legal issue. One example of the application of this principle, in combination with the application of the acte clair and acte éclairé doctrines, is the retroactive application of the Spanish horizontal tax group regime.

European Union

CCTB – Is There a Chance of a Breakthrough?

Lisa Aumayr and Gunter Mayr

The idea of a common consolidated corporate tax base (CCCTB) has been discussed in the European Union for more than 15 years. In June 2018, Germany and France agreed on a catalogue of reforms including the common corporate tax base (CCTB), which was intended to give the negotiations an extra boost. Against this backdrop, the Austrian Presidency of the Council of the European Union intensified work on the CCTB proposal. This article sheds some light on key issues regarding the CCTB.

European Union

Current Trends Regarding Disclosure Mechanisms: Reporting Ultimate Beneficial Ownership – Part 1

René Offermanns and Rita Botelho Moniz

In this two-part article, the authors comment on current trends regarding disclosure mechanisms. Part 1 of this article examines practical difficulties faced in complying with such mechanisms, the purpose and consequences of disclosure mechanisms and important considerations in implementing disclosure mechanisms. Part 2, to be published in issue 5 of European Taxation (2019), examines the reporting of beneficial ownership.


Specific Anti-Avoidance Measures in Greece in the Post-BEPS and Post-ATAD Era

Aikaterini Savvaidou and Vasiliki Athanasaki

In this article, the authors outline the Greek anti-avoidance legal framework, as currently in force, focusing on specific anti-avoidance rules. Further, they compare these provisions to the BEPS anti-abuse measures and the EU Anti-Tax Avoidance Directive (2016/1164).

Mery Alvarado
Mery Alvarado

Corporate Tax Changes Implementing the EU Anti-Tax Avoidance Directive (2016/1164) and Other Developments

Lubka Tzenova

This note discusses changes to the Corporate Income Tax Act in respect of the introduction of new tax rules for certain operating lease agreements, a new interest deduction limitation rule, amendments to the thin capitalization rule and the controlled foreign company (CFC) rule, and other amendments relating to implementation of the EU Anti-Tax Avoidance Directive (2016/1164).


German Transfer Pricing Rules Incompatible with EU Law – A Critical Assessment of the ECJ’s Hornbach-Baumarkt (Case C-382/16) Decision

Xaver Ditz and Carsten Quilitzsch

In this note, the authors examine the ECJ’s decision in Hornbach-Baumarkt (Case C-382/16), which addresses whether or not section 1 of the German Foreign Tax Act, which provides for income adjustments to non-arm’s length transfer prices in respect of business relations with non-resident related parties but not in respect of purely domestic transactions, breaches EU law.


Group Taxation and Further Corporate Income Tax Changes Effective 2019

Roland Felkai

On 1 January 2019, Hungary introduced a number of noteworthy new regulations, in particular a group taxation regime, which are described in this article together with other corporate income tax developments.


The New Special Tax Regime for Inbound Pensioners

Giorgio Beretta

This note discusses the new special tax regime for inbound pensioners, pursuant to which foreign pensioners transferring their tax residence to the southern regions of Italy can opt to pay a lump-sum substitute tax of 7% per year, in lieu of ordinary taxation, on all non-Italian-sourced income.

Slovak Republic

Exit Tax in the Slovak Republic

Zuzana Blažejová

Due to mandatory implementation of the EU Anti-Tax Avoidance Directive (2016/1164) (hereinafter ATAD), the Slovak Republic was required to implement, with effect from 1 January 2018, an entirely new concept of taxation, i.e. exit tax.

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