The CFE ECJ Task Force has prepared an Opinion Statement on the Sofina-case, in which the Fifth Chamber of the Court of Justice of the EU delivered its decision on 22 November 2018. In the decision, the Court held that the imposition of French dividend withholding tax...
CFE Tax Advisers Europe acknowledges that the “Danish beneficial ownership cases” address a number of important and timely issues, especially with regard to the concept of abuse in EU law. Those include (1) the expansion of the general anti-abuse principle enshrined...
CFE Tax Advisers Europe has published an Opinion Statement on the Court of Justice decision of 12 June 2018, in Case C-650/16 Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment and the viability of the Marks...
CFE welcomes the ECJ Eqiom judgment. In an international context where the fight against tax avoidance and aggressive tax planning is intensifying, it is important to preserve the fundamental principles of a balanced tax system: free choice of the least taxed route,...
CFE Tax Advisers Europe has published an Opinion Statement ECJ-TF 1/2018 on the Compatibility of Limitation-on-Benefits (LoB) Clauses with the EU Fundamental Freedoms. The Opinion Statement argues that the LoB clauses contained in Double Taxation Treaties are likely...
