…to the standpoint of the Directorate-General Competition in the context of EU State aid that companies of MNE’s and standalone companies should be to be treated equally. What is clear…
…in comparison to the early comments presented to the ATAD. Some MS seemingly expect to carry out as little changes as at all possible. Having said this we sincerely believe,…
…Functioning of the European Union, particularly with regard to intermediate and other holding companies. The material requirements for the establishment of intermediate or other holding companies are relatively marginal. An…
…mit beschraenkter Haftung” – GmbH (limited liability company). In practice, the GmbH is commonly used for holding companies due to its uncomplicated formation and simplified corporate governance. The Normative Instruction…
…now add a question here. On August 30th this year, the European Commission released its final decision in the Apple case. According to the European Commission, the two Irish tax…
…on their treaty partners. Maybe because a) they suspect that their counter part competent authorities know ‘the game’ better than judges do and b) their counter part competent authorities may…
…3). Clearly when comparing your company to BvD 1, the results seem comparable, whilst in comparison to BvD 2, your profit margin is 2,5% higher. However, it will be wrong…
Introduction. I have been actively supporting an EU based corporate income tax to reflect the single internal market rather than a fragmented framework with 28 competing tax laws. I’ve done…
…Commission – Press release IP/16/3085). The Commission view this as inconsistent application of national law, giving rise to a discretionary double non-taxation in the same vein as the MacDonald’s ruling….
…decisions of the EU courts bind the national jurisdictions? And what about the decisions of the VAT Committee? In the end, it seems that the most likely option is for…
…transactions concerning intangibles. Two frequently debated issues refer to transfer pricing proceedings and the burden of proof, as well as documentary duties multinational companies have to comply with, whenever required,…
…tougher tax rules on trusts’ (Reuters, 4 July 2016) <http://www.reuters.com/article/us-britain-eu-tax-trusts-idUSKCN0ZK1ER?utm_campaign=trueAnthem:+Trending+Content&utm_content=577ab35e04d3011771ef237b&utm_medium=trueAnthem&utm_source=twitter> accessed 5 July 2016. [16] Council Directive 2009/133/EC of 19 October 2009 on the common system of taxation applicable to…
…political questions. (1)The Commission applies a “New Approach” in its investigations by collapsing advantage and selectivity and comparing multi-nationals to domestic companies The first complaint goes right to the heart…
…and, hence, the new comments became rapidly outdated and useless. It is self-evident that borderless digital economy’s business models are nowadays much more rich, complex, and sophisticated than e-commerce state…
