Opinion Statement ECJ-TF 2/2016 on the Case C-18/15, on the admissibility of gross withholding taxation of interest

2018-05-15T14:11:27+01:00

This is an Opinion Statement prepared by the CFE ECJ Task Force on Case C-18/15, in which the 5th Chamber of the Court of Justice of the European Union (ECJ) delivered its judgment on 13 July 2016, following the opinion of Advocate General Juliane Kokott of 17 March 2016. It is a response to [...]

Opinion Statement ECJ-TF 1/2016 on the Cases C-10/14, C-14/14, X, and C-17/14, on the Dutch dividend with-holding tax

2018-05-15T13:00:48+01:00

This is an Opinion Statement prepared by the CFE ECJ Task Force on combined Cases C-10/14, C-14/14 and C-17/14, in which the 3rd Chamber of the Court of Justice of the European Union (ECJ) delivered its judgment on 17 September 2015, following the Opinion of Advocate General Jääskinen of 25 June 2015. The cases [...]

Opinion Statement ECJ-TF 4/2015 on the Case C-386/14, on the French “intégration fiscale”

2018-05-16T08:16:20+01:00

This is an Opinion Statement prepared by the CFE ECJ Task Force on Case C-386/14, in which the 2nd Chamber of the Court of Justice of the European Union (ECJ) delivered its judgment on 2 September 2015, following the opinion of Advocate General Kokott of 11 June 2015. The judgment, which has also been [...]

Opinion Statement ECJ-TF 3/2015 on the Case C-512/13, on “horizontal discrimination”

2018-05-15T14:54:01+01:00

This is an Opinion Statement prepared by the CFE ECJ Task Force on Case C-512/13, C.G. Sopora, which was decided by the Grand Chamber of the Court of Justice of the European Union (ECJ) on 24 February 2015. DOWNLOAD

Opinion Statement ECJ-TF 2/2015 on the Case C-172/13, concerning the “Marks & Spencer exception”

2018-05-15T14:04:10+01:00

This is an Opinion Statement prepared by the CFE ECJ Task Force on Case C-172/13, European Commission v United Kingdom, which was decided by the Grand Chamber of the Court of Justice of the European Union (ECJ) on 3 February 2015. This case is in some ways a follow-up to the ECJ’s decision in [...]

Opinion Statement ECJ-TF 3/2014 on the case C-164/12, concerning taxation of unrealized gains upon a reorganisation within the EU

2018-05-15T14:50:17+01:00

This is an Opinion Statement prepared by the CFE ECJ Task Force on Case C-164/12, DMC. After illustrating the facts of the DMC case and the preliminary questions, this document will focus on selected critical points from this case by pointing out some differences between it and its most immediate relevant precedent, National Grid [...]

Opinion Statement ECJ-TF 1/2014 on the case C-617/10, Åkerberg Fransson

2018-05-15T11:25:24+01:00

Opinion Statement ECJ-TF 1/2014 of the CFE on the decision of the European Court of Justice in case C-617/10, Åkerberg Fransson, concerning ne bis in idem in tax law. This Opinion Statement comments only on the issues of particular interest for taxpayers and their advisors. It does therefore not deal with the judgment insofar [...]