EU Tax Alert

• 01-03-2018 EU TAX ALERT 2018/05
  
  Cases C-115/16, C-116/16, C-117/16, C- 118/16, C-119/16 and C-299/16
  
  

  AG Kokott issued her opinion on the interpretation of the Parent Subsidiary Directive and the Interest and Royalty Directive in the Danish conduit cases
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• 22-02-2018 EU TAX ALERT 2018/04
  

  Cases C-398/16 X BV and C-399/16 X NV
  CJEU rules on compatibility with freedom of establishment of Dutch provisions limiting the deduction of interest expenses and currency losses in cases of investments in foreign subsidiaries

  Case C-28/17, NN
  AG Campos Sánchez-Bordona issued his opinion on the compatibility with the TFEU of Danish legislation limiting the use, within domestic fiscal units, of losses incurred by Danish PEs of EU companies

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• 07-02-2018 EU TAX ALERT 2018/03
  
  AG Wathelet issued his opinion on the compatibility with the free movement of capital of German rules on the taxation of dividends from third countries 
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• 26-01-2018 EU TAX ALERT 2018/02
  
  The EU Commission requests Italy to eliminate the tax restriction on the investments in Italian real estate made by non-resident EU citizens 
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• 17-01-2018 EU TAX ALERT 2018/01
  
  Case C-650/16, Bevola

  
  AG Campos Sánchez-Bordona issued his opinion on the compatibility with the freedom of establishment of the Danish legislation precluding the deductibility in Denmark of final losses incurred by foreign PEs
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• 20-12-2017 EU TAX ALERT 2017/08
  
  The CJEU confirms that (i) TP adjustments are not relevant for declaring import taxable base of goods (Case C-529/16 Hamamatsu Photonics Deutschland GmbH) and that (ii) general presumptions of fraud and abuse are not compatible with the Parent Subsidiary Directive and the freedom of establishment (Joined cases C-504/16 Deister Holding and C-613/16 Juhler Holding)
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• 14-12-2017 EU TAX ALERT 2017/07
  
  Case C-382/16 Hornbach-Baumarkt
  
  

  AG Bobek issues his opinion on compatibility of German transfer pricing legislation with the freedom of establishment
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• 05-12-2017 EU TAX ALERT 2017/06
  
  The ECOFIN approved (i) the EU list of non-cooperative jurisdictions in taxation matters and (ii) the conclusions on the taxation of profits in the digital economy
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• 27-11-2017 EU TAX ALERT 2017/05
  
  The CJEU ruled on the interpretation of Art. 90 of VAT Directive concerning “VAT on bad debt relief” and the relevant Italian Implementing provision (Case C-246/16 Enzo Di Maura)
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• 23-11-2017 EU TAX ALERT 2017/04
  
  The Court of Justice of the European Union (“CJEU”) ruled on (i) the immediate taxation of gains from the transfer of a foreign PE (Case C-292/16 A Oy) and (ii) the direct applicability of the general principle of prohibition of abuse to EU secondary tax legislation (Case C-251/16 Cussens)
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