by brodiemcintosh | Jun 6, 2025
CFE Tax Advisers Europe has published an Opinion Statement calling for a temporary pause in the application of the extra-territorial rules under the EU Minimum Tax Directive—specifically the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR)—on the...
by brodiemcintosh | Oct 2, 2024
The CFE ECJ Task Force has issued an Opinion Statement on the decision in the Commission v Ireland (“Apple”) case, C-465/20, in which the Court of Justice of the EU (Grand Chamber) delivered its decision on 10 September 2024. The Apple case concerns the...
by brodiemcintosh | Jul 10, 2023
The CFE ECJ Task Force has issued an Opinion Statement on the ECJ decision of 16 February 2023 in Case C-707/20, Gallaher Limited, the last UK direct tax case before the CJEU. Gallaher concerns the compatibility of the United Kingdom’s group transfer rules with EU...