On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more
On September 24, 2019, the EU General Court (General Court) issued its long-awaited judgments in relation to the appeals brought against two European Commission (EC) decisions of 2015 concluding that tax rulings granted by...more
9/30/2019
/ Arm's Length Principle ,
Benchmarks ,
Business Profits ,
Corporate Counsel ,
Corporate Taxes ,
European Commission ,
Fiat ,
General Court of the European Union (GCEU) ,
Luxembourg ,
Member State ,
Netherlands ,
Regulatory Authority ,
Starbucks ,
State Aid ,
Tax Litigation ,
Treaty on the Functioning of the European Union (TFEU)
On August 20, 2018, the U.K. government published further details of its negotiation position with the European Union on state aid post-Brexit. Three days later, it published guidance on state aid in case the U.K. leaves the...more
On March 21, 2018, the European Commission released a draft legislative package for “fair taxation of the digital economy,” which would establish new tax rules for digital business activities within the European Union. This...more
3/27/2018
/ Business Profits ,
Digital Single Market ,
Digital Taxes ,
Double Taxation ,
Economic Presence Nexus ,
EU ,
EU Single Market ,
European Commission ,
Gig Economy ,
Member State ,
OECD ,
Tax Reform ,
Tax Treaty
Europe’s politicians worry that international tax rules have not kept pace with the digital economy and too easily allow multinationals to organize their global operations to minimize net taxable profits in high-tax European...more
1/23/2018
/ Corporate Taxes ,
Digital Assets ,
EU ,
European Commission ,
France ,
International Tax Issues ,
Italy ,
Multinationals ,
OECD ,
State Aid ,
Tax Reform ,
UK
On 26 October 2017, the European Commission (the Commission) opened an in-depth investigation into UK statutory rules that exempt certain financing income earned by foreign subsidiaries of UK corporate taxpayers from UK tax....more
10/31/2017
/ Anti-Avoidance ,
Antitrust Investigations ,
Business Income ,
Controlled Foreign Corporations ,
Corporate Taxes ,
EU ,
European Commission ,
Financing ,
Foreign Subsidiaries ,
Multinationals ,
State Aid ,
Statutory Requirements ,
Tax Exemptions ,
Treaty on the Functioning of the European Union (TFEU) ,
UK ,
UK Brexit
UK Prime Minister Theresa May today served formal notification of the UK’s intention to withdraw from the European Union (EU) pursuant to Article 50 of the Treaty of Lisbon. This action commences a period of up to two years...more
Michel Barnier, vice president of the European Commission, recently wrote to the chairman of the European Banking Authority (the EBA), asking the EBA to report by the end of this month on whether allowances paid by EU banks...more
U.K.’s challenge to the proposed financial transaction tax (FTT), while recognizing that the U.K.’s challenge was precautionary — and possibly premature.
The U.K. was challenging the European Council’s Decision...more
By the end of this year, the European Commission will present its legislative proposals for EU banking structural reform. Once the proposals are implemented, EU banks will have to separate their “investment” business from...more
The European Council Legal Service has issued an opinion that seriously questions the legal validity of the European Commission’s proposals for a financial transaction tax (FTT). The opinion finds that the extraterritorial...more