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Opinion Statement ECJ-TF 3/2018 on the Case C-650/16, Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment

Opinion Statement ECJ-TF 3/2018 on the Case C-650/16, Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment

by | Nov 15, 2018

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...
Opinion Statement ECJ-TF 3/2018 on the Case C-650/16, Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment

ECJ Opinion Statement on the Case C-6/16, Eqiom, concerning compatibility of the French anti-abuse rule regarding outbound dividends with the Parent-Subsidiary Directive and the EU fundamental freedoms

by | May 30, 2018

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,...
Opinion Statement ECJ-TF 3/2018 on the Case C-650/16, Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment

Opinion Statement ECJ-TF 1/2018 on the Compatibility of Limitation-on-Benefits (LoB) Clauses with the EU Fundamental Freedoms

by | Apr 30, 2018

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...
Opinion Statement ECJ-TF 3/2018 on the Case C-650/16, Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment

ECJ-TF Opinion Statement 4/2017 on the decision of the Court of Justice of the EU in Case C-283/15, X

by | Jan 15, 2018

This Opinion Statement comments on the decision of 9 February 2017 of the Court of Justice of the EU in Case C-283/15, X (“pro-rata personal deductions”), concerning personal and family tax benefits in multi-state situations. We invite you to read the Opinion...
Opinion Statement ECJ-TF 3/2018 on the Case C-650/16, Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment

ECJ-TF Opinion Statement 3/2017 on the judgment of the Court of Justice of the EU in Case C-682/15, Berlioz Investment Fund SA

by | Jan 8, 2018

This is an Opinion Statement prepared by the CFE ECJ Task Force on the Case C-682/15, Berlioz Investment Fund SA, in which the Grand Chamber of the Court of Justice of the European Union (ECJ) delivered its judgment on 16 May 2017, following the Opinion of Advocate...
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