November 2017  
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European Taxation
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Issue No. 11 - 2017 of the European Taxation is now available online.

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Number 11 - 2017 contains the following:
European Union

Bridging the CCCTB and the Arm’s Length Principle – A Value Chain Analysis Approach

René Offermanns, Steef Huibregtse, Louan Verdoner and Jakub Michalak

This article provides an analysis of the proposals for a common consolidated tax base (CCTB) and common consolidated corporate tax base (CCCTB) in the European Union in the context of transfer pricing, concluding that a value chain analysis approach is the only possible means of aligning the CCCTB rules with the arm’s length principle.


The Taxation of Trusts in Portugal

Francisco de Sousa da Câmara

The author provides a historical overview of the recognition of trusts in Portugal, focusing on international private law and civil rules, the tax landscape surrounding a foreign trust, the recent tax treatment of trusts in Portugal and the challenges that lie ahead.

European Union

Did the ECJ Go Too Far in Brisal (Case C-18/15)?

João Sérgio Ribeiro

In this article, the author provides a critique of the ECJ’s decision in Brisal (Case C-18/15), arguing that the ECJ went too far in equating residents with non-residents with regard to the deduction of expenses, with the result that an excessive administrative burden has been placed on both tax authorities and taxpayers. In the end, the decision covertly encourages Member States to give up source taxation of interest.

Oana Popa
Oana Popa
Court of Justice
Oana Popa

Opinion Statement FC 3/2017 on the Proposed Directives for the Introduction of a Common Corporate Tax Base and Common Consolidated Corporate Tax Base

CFE Fiscal Committee

This CFE Opinion Statement, submitted to the European Institutions on 9 June 2017, discusses the proposed directives for the introduction of a common corporate tax base and common consolidated corporate tax base.

European Union

Thin Capitalization Rules and Corresponding Tax Exemptions: All or Nothing

Gerard Meussen

The author, in this note, discusses the ECJ’s decision in Masco Denmark (Case C-593/14), which addresses the issue of thin capitalization rules that provide for an equivalent tax exemption for interest income in domestic situations only.


Footballer’s Share of a Transfer Fee and the Quasi-Payroll Tax on Excessive Severance Payments

Dick Molenaar

This note examines two conflicting Netherlands decisions regarding the applicability of the quasi-payroll tax on excessive severance payments to a footballer’s share of a transfer fee.

United Kingdom

Preparing for Brexit: A Note on the European Union (Withdrawal) Bill

Belema Obuoforibo

This note addresses what the United Kingdom’s laws will look like after withdrawal from the European Union. In particular, the author summarizes the main points of the EU (Withdrawal) Bill, which sets out how EU law will operate in the United Kingdom after Brexit takes place.

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