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Opinion Statement ECJ-TF 3/2014 on the case C-164/12, concerning taxation of unrealized gains upon a reorganisation within the EU

Opinion Statement ECJ-TF 3/2014 on the case C-164/12, concerning taxation of unrealized gains upon a reorganisation within the EU

by | Dec 15, 2014

This is an Opinion Statement prepared by the CFE ECJ Task Force on Case C-164/12, DMC. After illustrating the facts of the DMC case and the preliminary questions, this document will focus on selected critical points from this case by pointing out some differences...
Opinion Statement ECJ-TF 3/2014 on the case C-164/12, concerning taxation of unrealized gains upon a reorganisation within the EU

Opinion Statement ECJ-TF 2/2014 on the case C-276/12, concerning taxpayer’s rights in case of exchange of information upon request

by | Apr 1, 2014

Opinion Statement ECJ-TF 2/2014 of the CFE on the decision of the European Court of Justice in caseC-276/12, Sabou, concerning taxpayer’s rights in case of exchange of information upon request. DOWNLOAD
Opinion Statement ECJ-TF 3/2014 on the case C-164/12, concerning taxation of unrealized gains upon a reorganisation within the EU

Opinion Statement ECJ-TF 1/2014 on the case C-617/10, Åkerberg Fransson

by | Feb 15, 2014

Opinion Statement ECJ-TF 1/2014 of the CFE on the decision of the European Court of Justice in case C-617/10, Åkerberg Fransson, concerning ne bis in idem in tax law. This Opinion Statement comments only on the issues of particular interest for taxpayers and their...
Opinion Statement ECJ-TF 3/2014 on the case C-164/12, concerning taxation of unrealized gains upon a reorganisation within the EU

Opinion Statement ECJ-TF 4/2013 on the case C-425/11, concerning personal tax benefits in Germany for Swiss residents

by | Dec 15, 2013

This Opinion Statement analyses the ECJ decision on the Case C-425/11 Katja Ettwein, concerning a personal tax advantage for self-employed frontier workers under the 2002 ECSwitzerland Agreement on the free movement of persons (the “Agreement”)....
Opinion Statement ECJ-TF 3/2014 on the case C-164/12, concerning taxation of unrealized gains upon a reorganisation within the EU

Opinion Statement ECJ-TF 3/2013 on the case A Oy (C-123/11) and the use of cross-border losses

by | Jul 1, 2013

This Opinion Statement analyses Case C-123/11 A Oy, concerning the possibility of using Swedish losses in Finland following a merger which made the losses unusable in Sweden. DOWNLOAD
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