Opinion Statement CFE 1/2025 on the OECD Inclusive Framework BEPS Package Stocktake Exercise

by brodiemcintosh | Jul 7, 2025

The OECD/G20 Inclusive Framework is currently undertaking a stocktake exercise to examine research and evidence on the economic and behavioural impacts of the BEPS Project, both in aggregate and for each of the 15 Actions. A report will be published ahead of the...

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

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...

Opinion Statement ECJ 2/2024 on Case C-465/20, the Commission v Ireland (“Apple”)

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...

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

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...

Opinion Statement on Issues With the Supply of Goods With Transport Under e-Commerce Rules

by | Jul 16, 2021

Determining the nature of a transaction is one of the most important steps when determining the VAT treatment of supplies, including how the place of supply rules operate. It is only after the nature of a supply has been determined, including determining whether a...