European Tax

A recent UK tax tribunal decision, relating to the UK corporation tax treatment of a “tower” structure, serves as a useful reminder of...

In a decision dated 23 October 2018 (I R 54/16), but only published on 17 April 2019 the German Federal Fiscal Court (Bundesfinanzhof –...

Pretty much any German inbound-investment has to consider how profits can be extracted in the most tax-efficient manner. In principle,...

Two ECJ rulings of 26 February 2019 cast doubt on whether safe harbour rules applied by the Netherlands are compliant with EU law.  Under...

The full decision in the EU State aid investigation into the UK CFC rules for non-trading finance profits (“NTFP”) has now been...

With the OECD issuing its February 2019 public consultation, in which a consensus-based and long-term solution for the taxation of the...

In the recent case of Gallaher, the UK’s First-tier Tax Tribunal reached a surprising conclusion on the UK’s intra-group transfer regime....

The "marketing intangibles" proposal has emerged from the OECD's public consultation discussions as the most likely of the OECD's...

Discussions continue at a global level on how the international tax rules should be reformed so they work adequately for today’s business...

In 2017 the OECD asked a group (made up of the UK and Italian tax authorities) to look at how countries could ensure that income from the...