European Court annuls the decision of the European Commission that Excess Profit rulings are State Aid
The General Court decided that the European Commission has made an error in its decision where it concluded that the Belgian excess profit regime resulted in a so-called ‘State aid scheme’. As a result of this approach under a State aid scheme (rather than assessing each of the rulings involved), the European Commission limited its
CJEU holds German RETT exemption for group restructurings not to be State aid in upstream merger case
On 19 December 2018, the Court of Justice of the European Union (CJEU) issued its judgment in the case of A-Brauerei (C-374/17). A brief overview of the judgment can be found via this PwC EUDTG Newsalert – 20 December 2018 (CJEU holds German RETT exemption_ for group restructurings not to be State aid in upstream merger_ case)
DAC6 – EC’s feedback on the questions raised by Member States
On 24 September 2018, EU Member States dedicated the entire meeting of the European Commission (EC)’s Working Party IV to seeking more clarity from the EC concerning the interpretation of Council Directive 2018/822/EU of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to
EU Direct Tax Newsalert: EU Commission finds that Luxembourg did not grant State aid to McDonalds
On 19 September 2018, the European Commission (“EC”) issued a press release concerning its final decision in the State aid investigation into tax rulings granted by the Luxembourg tax authorities to a Luxembourg subsidiary of the McDonald’s group in relation to the treatment of a branch established in the United States of America (“US”). The
EU Commission finds that Luxembourg gave State aid to GDF Suez (now Engie)
On 20 June 2018 the European Commission (“EC”) issued a press release concerning its final decision in the State aid investigation into tax rulings granted by the Luxembourg tax authorities to GDF Suez group (now Engie) (“the Group”) in relation to the treatment of certain financing transactions. The EC considered that the Group received an
EMEA ITS Webcast – How mandatory disclosure for intermediaries (DAC6) impacts multinationals
As per our previous update, the ECOFIN Council formally adopted – on 25 May 2018 – the directive on mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements – also known as DAC6. As the directive will already enter into force in the next weeks and will have an
