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

by brodiemcintosh | May 21, 2025

CFE Tax Advisers Europe has published an Opinion Statement prepared by its ECJ Task Force on the Nordcurrent Group UAB case, Case C-228/24 (the “Nordcurrent Case”), in which the Court of Justice of the EU (Sixth Chamber) delivered its decision on 03 April...

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

by brodiemcintosh | Feb 25, 2025

The CFE has issued an Opinion Statement prepared by the CFE ECJ Task Force on the decisions of the CJEU in C-694/20 and Case C-623/22 on the validity of certain aspects of DAC6 as regards the Charter of Fundamental Rights of the European Union (the “DAC6 cases”). 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 1/2024 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

by brodiemcintosh | Mar 10, 2024

The CFE ECJ Task Force has issued an Opinion Statement on the decision of the CJEU of 5 December 2023 in Joined Cases C-451/21P and C-454/21P, Engie, on alleged State aid in relation to a deduction/non-inclusion structure in Luxembourg. The Engie case concerns the...

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

by brodiemcintosh | Dec 19, 2023

The CFE ECJ Task Force has issued an Opinion Statement on the the EFTA Court’s decision of 4 July 2023 in case Case E-11/22, RS, concerning compatibility with the fundamental freedoms of a municipal surcharge distinguishing between residents and non-residents...