LATEST NEWS
CFE’s Tax Top 5 – 30 June 2025
BRUSSELS | 30 JUNE 2025 Global Minimum Tax Uncertainty Following G7 Agreement for US Multinationals The G7 has issued a Statement that could significantly reshape the global minimum tax framework developed under the OECD/G20 Inclusive Framework. The statement sets out...
CFE’s Tax Top 5 – 23 June 2025
BRUSSELS | 23 JUNE 2025 ECOFIN Ministers Advance EU Customs Reform & Review Tax Related Progress Under Polish Presidency At the 20 June 2025 meeting of the ECOFIN Council, EU Finance Ministers reviewed progress across several taxation files, formally...
CFE’s Tax Top 5 – 16 June 2025
BRUSSELS | 16 JUNE 2025 EU Updates List of High-Risk Third Countries for AML Compliance The European Commission has revised its list of high-risk third-country jurisdictions with deficiencies in their anti-money laundering and countering the financing of terrorism...
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PUBLICATIONS

Opinion Statement 2/2025 on the Introduction of a Temporary Pause of Pillar 2 Extra-Territorial Rules (IIR & UTPR) Under Article 32 EU Minimum Tax Directive

Opinion Statement ECJ 2/2025 on the Interpretation of the Anti-abuse Provision in the Parent Subsidiary Directive in Case C-228/24, Nordcurrent

Opinion Statement FC 1/2025 on the VAT Treatment of Chain Transactions Involving Imports into the EU

Opinion Statement ECJ 1/2025 on Legal Professional Privilege and the Validity of Certain Provisions of DAC6 in light of the Charter of Fundamental Rights of the European Union & CJEU Decisions in C-694/20 Orde van Vlaamse Balies and C-623/22 Belgian Association of Tax Lawyers

Opinion Statement PAC 1|2024 on Evaluation of the Directive on Administrative Cooperation in the Field of Taxation

Opinion Statement FC 4/2024 on Evidence to Support Transport Organised by the Customer Under Article 138 of the VAT Directive

Opinion Statement FC 2/2024 Responding to the EU Commission Consultation on Dispute Resolution Mechanisms in the European Union

Opinion Statement ECJ-TF 1/2024 on Joined Cases C-451/21P and C-454/21P, Engie, on alleged State aid in relation to a deduction/non-inclusion structure in Luxembourg

Opinion Statement ECJ-TF 4/2023 on EFTA Court Case E-11/22, RS: Compatibility with fundamental freedoms of a municipal surcharge distinguishing between residents and non-residents for the purposes of the applicable rate

Opinion Statement ECJ-TF 3/2023 on Case C-322/22: Right to be paid interest on overpayment of taxes in breach of EU Law

Opinion Statement ECJ-TF 2/2023 on Case C-83/21, Airbnb Ireland and Airbnb Payments UK on accessory tax obligations imposed on digital service providers

Opinion Statement ECJ-TF 1/2023 on Case C-707/20, Gallaher Limited, on the taxation of capital gains in intra-group transfers

Opinion Statement PAC 1/2023 on the European Parliament Report on Lessons Learned from the Pandora Papers

Opinion Statement FC 5/2023 on Official Ruling 57:2023 of the Italian Central Tax Office on Intervening Fixed Establishments in a VAT Context

Opinion Statement FC 4/2023 on the EU Commission VAT in the Digital Age Legislative Proposal Package

Opinion Statement FC 1/2023 on the European Commission Public Consultation on the Introduction of a New Corporate Taxation System in Europe (BEFIT)Opinion Statement

Opinion Statement ECJ-TF 4/2022 on the ECJ decision in Case C-538/20, W AG, on the deductibility of foreign final losses

Opinion Statement ECJ-TF 3/2022 on the EFTA Court decision of 1 June 2022 in Case E-3/21, PRA Group Europe, on the discriminatory interaction between the “interest barrier” and group contributions

Opinion Statement PAC 1/2022 on the European Commission Public Consultation on the Proposed Directive on Securing the Activity Framework of Enablers (“SAFE”) Proposed Directive

Opinion Statement FC 6/2022 on the European Commission Proposal for a Council Directive on debt-equity bias reduction allowance (‘DEBRA Proposal’)

Opinion Statement FC 4/2022 on Possible Solutions to Inheritance and Gift Double Taxation Issues Within the EU

Opinion Statement ECJ-TF 2/2022 on the CJEU decision in Case C-788/19, European Commission v Kingdom of Spain (Form 720)

Opinion Statement TTC 1/2022 on the OECD Public Consultation on a Crypto-Asset Reporting Framework and Amendments to the Common Reporting Standard

Opinion Statement FC2/2022 on the EU Proposal on Fighting the Use of Shell Entities and Arrangements for Tax Purposes (Unshell Proposal)

Opinion Statement FC 1/2022 on the EU Proposal for a Directive on Minimum Tax & OECD Model Rules Implementing Pillar 2 (Global Minimum Taxation)

Opinion Statement ECJ-TF 1/2022 on the CJEU decision in Case C-437/19, État luxembourgeois v L, on the conditions for information requests and taxpayer remedies

Opinion Statement ECJ-TF 3/2021 on the CJEU decision in Case C-388/19, MK v Autoridade Tributária e Aduaneira, on the taxpayers’ option to avoid discriminatory taxation of capital gains

Opinion Statement ECJ-TF 1/2021 on the CJEU decision in Case C-484/19, Lexel AB, concerning the application of Swedish interest deductibility rules

Opinion Statement on the European Commission Initiative/Roadmap for Reform on Cross-Border Provision on Professional Services of March 2021

Opinion Statement FC 7/2020 on the EU Consultations on the Carbon Border Adjustment Mechanism & Energy Taxation Directive

Opinion Statement ECJ-TF 3/2020 on the General Court judgments in Cases T-778/16 and T-892/16, Ireland v. Commission and Apple v. Commission

Opinion Statement PAC 4/2020 on the European Commission Initiative/Roadmap for Communication and Recommendation to Improve the Situation of Taxpayers in the Single Market

Opinion Statement ECJ-TF 2/2020 on the CJEU decision in Case C-75/18, Vodafone, on progressive turnover taxes

CFE Opinion Statement CFE 1/2020 on the potential Commission initiative to strengthen the Directive on Administrative Cooperation in Direct Taxation

CFE Opinion Statement FC 3/2020 on the Directive on Tax Dispute Resolution Mechanisms in the European Union

Opinion Statement ECJ-TF 4/2019 on the CJEU decision in Case C-135/17, X-GmbH, concerning the application of the German CFC legislation in relation to third countries

Opinion Statement on the Commission consultation on amending Directive 2006/112/EC, as regards provisions relating to distance sales of goods and certain domestic supplies of goods

Opinion Statement ECJ-TF 3/2019 on the CJEU decision of 22 November 2018 in Case C-575/17, Sofina, on withholding taxes, losses and territoriality

Opinion Statement on the CJEU Case C-382/16 Hornbach (Transfer-Pricing/ Commercial Justification for Breach of the Arm’s Length Principle)

CFE Opinion Statement FC 9/2018 on the notion of “minimal human intervention” in the definition of “electronically supplied services”

Opinion Statement FC 5/2018 – Practical Difficulties Arising from the Practices and Procedures of the CJEU

Opinion Statement ECJ-TF 3/2018 on the Case C-650/16, Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment

Opinion Statement FC 7/2018 as regards the Commission proposal to introduce detailed technical measures for the operation of the definitive VAT system

Opinion Statement PAC 5/2018 on the legal professional privilege reporting waiver set out in the EU Mandatory Disclosure Rules Directive (DAC6)

Opinion Statement FC 6/2018 on a Proposal for a Council Directive amending Directive 2006/112/EC, on the common system of value added tax as regards the special scheme for small enterprises

Opinion Statement on a Proposal for a Council Directive amending Directive 2006/112/EC, as regards rates of Value Added Tax (COM(2016)758 final, of 1 December 2017 and COM/2018/20 of 28 January 2018)

ECJ Opinion Statement on the Case C-6/16, Eqiom, concerning compatibility of the French anti-abuse rule regarding outbound dividends with the Parent-Subsidiary Directive and the EU fundamental freedoms

Opinion Statement ECJ-TF 1/2018 on the Compatibility of Limitation-on-Benefits (LoB) Clauses with the EU Fundamental Freedoms

ECJ-TF Opinion Statement 4/2017 on the decision of the Court of Justice of the EU in Case C-283/15, X

FC Opinion Statement 10/2017 – Position Paper on the EU Public Consultation on the Fair Taxation of the Digital Economy

FC Opinion Statement 09/2017 on the European Commission Proposals on the way towards a single European VAT area

CFE Opinion Statement FC 08/2017 Response to OECD request for input regarding tax and digitalisation

ECJ-TF Opinion Statement 3/2017 on the judgment of the Court of Justice of the EU in Case C-682/15, Berlioz Investment Fund SA

Opinion Statement FC 05/2017 VAT exemption of services provided by an independent group of persons (Article 132 (1) (f) of Directive 2006/112/EC)

Opinion Statement FC 4/2017 on the proposed Directive on Double Taxation Dispute Resolution Mechanisms in the European Union

Opinion Statement FC 3/2017 on the proposed Directives for the introduction of a Common Corporate Tax Base & Common Consolidated Corporate Tax Base

Opinion Statement FC 02/2017 on the Response to Consultation on the OECD BEPS Action 6 Public Discussion Draft on non-CIV examples

FC Opinion Statement 01/2017 – VAT Groupings & Related Issues Concerned with Fixed Establishments & the Cost Sharing Exemption

Opinion Statement PAC 2/2017 on the European Commission public consultation on protection of whistleblowers

Opinion Statement ECJ-TF 2/2017 on the Cases C-20/15 P and C-21/15 P, concerning the requirements of selec-tive aid in the sense of Art. 107 TFEU

Opinion Statement PAC/FC 1/2017 on the European Commission public consultation ‘Disincentives for advisers and intermediaries for potentially aggressive tax planning schemes’

Opinion Statement ECJ-TF 1/2017 on the Case C-464/14, concerning the free movement of capital and third countries

Opinion Statement FC 14/2016 on the OECD Discussion Draft on Branch mismatch structures (BEPS Action 2)

Opinion Statement FC 13/2016 on the OECD Discussion Draft (BEPS Action 7) Additional guidance on the attribution of profits to permanent establishments

Opinion Statement FC 12/2016 on the OECD Public Discussion Draft (BEPS Actions 8-10) Revised Guidance on Profit Splits

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

Opinion Statement FC 11/2016 on the OECD Public Discussion Draft (BEPS Action 4) Elements of the design and operation of the group ratio rule

Opinion Statement PAC 3/2016 and FC 9/2016 on the draft Report on tax rulings and other measures similar in nature or effect

Opinion Statement FC 3/2016 on the European Commission´s proposal for an Anti-Tax Avoidance Directive

Opinion Statement FC 2/2016 on the VAT treatment of cross-border services connected with immovable property

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

Opinion Statement ECJ-TF 4/2014 on the Cases C-39/13, C-40/13 and C-41/13, on the requirements to form “fiscal unity”

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