European Commission announces final State aid decision on financing income exemption within the UK’s CFC rules
On 2 April 2019, the European Commission (EC) announced that the Group Financing Exemption (GFE) within the UK Controlled Foreign Company (CFC) rules is “partly justified”. The decision has not yet been published but a brief explanation of the decision can be found via this link.
European Commission opens State aid investigation into Luxembourg’s tax treatment of Huhtamäki
On 7 March 2019, the European Commission (EC) announced the opening of an in-depth State aid investigation in a number of tax rulings granted by Luxembourg to Huhtamäki. This decision is another important decision in a range of decisions dealing with the taxation of intra-group financing activities. A brief explanation of the decision can be found
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
Commission requests that Belgium implements the judgment of the Court of Justice on the evaluation of rental income from immovable property
On 12 April 2018, the Court of Justice of the European Union (CJEU) ruled that the difference in tax treatment of immovable income, depending on whether the property is located in Belgium or in another State concerned an infringement of EU Law for which there is no justification. For immovable properties located in Belgium and
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
