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

by brodiemcintosh | Oct 3, 2023

The CFE ECJ Task Force has issued an Opinion Statement on the CJEU’s decision of 8 June 2023 in case C-322/22, E. v Dyrektor Izby Administracji Skarbowej we Wrocławiu, decided without an Opinion of the AG, concerning the right to be paid interest on overpayment of...

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

by brodiemcintosh | Jul 14, 2023

The CFE ECJ Task Force has issued an Opinion Statement on the ECJ decision of 22 December 2022 in case C-83/21, Airbnb Ireland and Airbnb Payments UK decided following the Opinion of AG Szpunar delivered on 7 July 2022. Inter alia, at issue was the compatibility with...

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

by brodiemcintosh | Dec 5, 2022

The CFE ECJ Task Force has issued an Opinion Statement on the ECJ decision of 22 September 2022 in Case C-538/20, W AG, on the deductibility of foreign final losses.  At issue in W AG was the ability of a German company to deduct the final losses which it had incurred...

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

by brodiemcintosh | Oct 17, 2022

The CFE ECJ Task Force has issued an Opinion Statement 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. At issue in PRA Group Europe was...