| Intertax 2007 |
| Title | Subject | Authors |
|---|
| 50d (3) EStG - entitlement to tax relief available to foreign companies: unofficial translation of the Federal Ministry of Finance Circular dated April 3, 2007 and Explanatory Notes.(Legislation) | Law | Ransch, Ulrich, Littan, Sonja, John, Alexandra |
| AG concludes Dutch dividend withholding tax exemption incompatible with EC law.(Advocate General Mengozzi interprets European Union treaty) | Law | Weening, Gerben, van den Hurk, Hans, Korving, Jasper |
| Appellate court affirms foreign tax credit reduction from indirect subsidy.(MONTHLY FEATURES)(US Tax Scene) | Law | Fuller, Thomas, Angle, Connie, Castanon, Richard |
| Article 24 (1) of the OECD Model Convention and the exclusion of MFN treatment - a comment on the OECD Public Discussion Draft.(Organisation for Economic Cooperation and Development Model Convention and Most Favored Nation treatment) | Law | Zalasinski, Adam |
| A single European market with 25 different corporate taxes? Fiscal disparity in Spain with regard to its future in the European Union. | Law | Calvo, Marta Bengoa, Poncela, Ana Carrera, Fernandez, Adolfo Cosme |
| Back to BASIC - stages of international tax planning or: getting the grip on a rocky road.(benchmarking, analysis, strategy, implementation, compliance) | Law | Kessler, Wolfgang, Eicke, Rolf |
| Belgian court requests ruling on whether tax relief under Parent-Subsidiary Directive requires full ownership of shares.(Court of Appeal of Liege) | Law | Rainer, Anno, Renier, Philippe |
| Belgian dividend deduction system referred to ECJ.(European Court of Justice) | Law | Renier, Philippe |
| Belgium: attribution of profits to permanent establishment.(Report) | Law | Wustenberghs, Tim |
| Burden and another v United Kingdom.(CASE LAW)(UK) | Law | Elliot, Peter |
| Can procedural rules create obstacles to fundamental freedoms in European Law? | Law | Furuseth, Eivind |
| CFC rules go up in smoke - with retro effect. | Law | Werlauff, Erik, Ronfeldt, Thomas, Vinther, Nikolaj |
| Commission takes steps against withholding tax on outbound dividends.(European Commission) | Law | Rainer, Anno |
| Common corporate consolidated tax base - don't forget the tax rates!(Editorial) | Law | Spengel, Christoph |
| Comprehensive approaches to company taxation in the European Union and cross-border corporate reorganizations. | Law | Durrschmidt, Daniel |
| Conference: 'Recent and Pending Cases at the ECJ on Direct Taxation', 15-17 February 2007, Vienna.(European Court of Justice) | Law | Fontana, Renata |
| Conference Report: The EU and Third Countries: Direct Taxation, 13-14 October 2006, Vienna.(European Union) | Law | Fontana, Renata |
| Corporate tax and the OECD.(Organization for Economic Cooperation and Development) | Law | Merks, Paulus |
| Cross-border trading in shares or participation in Spanish collective investment institutions: new Regime for accreditation of residence and provision of information. | Law | Giner, Luis Alfonso Martinez |
| Current scenario of the tax incentives in Brazil: a comparison based on the concepts of state aid in Europe and of the commerce clause in the United States. | Law | Catao, Marcos Andre Vinhas |
| ECJ allows application of German thin cap rules to interest paid to non-EU shareholder.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice decision on Germany's thin capitalization rule as it relates to non-European Union shareholders)(Case overview) | Law | Rainer, Anno |
| ECJ confirms non-application of basic freedoms of EC treaty between EU company and its third-country branch.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice) | Law | Rainer, Anno |
| ECJ requested to interpret merger directive in context of German requirement for double rollover of book value.(European Court of Justice) | Law | Rainer, Anno |
| ECJ rules French restrictions on exemption from annual real estate tax violate EC Treaty.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice, European Community) | Law | Rainer, Anno, Arras, Rachid, Keyhani, Sarvi |
| ECJ rules Hungarian HIPA may continue to be applied.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice, Hungarian local business tax) | Law | Rainer, Anno |
| ECJ rules on Austrian treatment of income from non-EU countries.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice decision on Austria's tax policy for non-European Union member countries) | Law | Weening, Gerben, van den Hurk, Hans, Korving, Jasper |
| ECJ rules on Finnish intragroup transfers.(European Court of Justice) | Law | Rainer, Anno |
| ECJ rules on tax deductibility of fees for foreign private schools.(MONTHLY FEATURES)(EC Tax Scene) | Law | Rainer, Anno, Nakhai, Katja |
| ECJ to rule on deductibilty of donations to non-resident charities.(European Court of Justice) | Law | Rainer, Anno |
| ECJ to rule on nondeductibility of write downs on shares in nonresident companies.(MONTHLY FEATURES)(EC Tax Scene)(European Court of Justice) | Law | Rainer, Anno |
| EC tax scene. | Law | |
| EC tax scene: ECJ rejects claim by nonresident companies for UK tax credits.(European Constitution Treaty)(European Court of Justice ) | Law | Thommes, Otmar, Tomsett, Eric, Rainer, Anno, Roels, Jan, Weening, Gerben, van den Hurk, Hans |
| EC tax scene: ECJ rules French withholding tax on outbound dividends violates EC treaty.(European Court of Justice)(European Constitution Treaty) | Law | Rainer, Anno |
| EC tax scene: ECJ rules on UK corporate taxation of foreign source dividends.(European Court of Justice)(Treaty establishing a Constitution for Europe) | Law | Thommes, Otmar, Tomsett, Eric, Rainer, Anno, Roels, Jan, Weening, Gerben, van den Hurk, Hans |
| EC tax scene.(European Community)(EC Merger Directive and group interest box) | Law | Rainer, Anno, Weening, Gerben, van den Hurk, Hans, Korving, Jasper |
| EC tax scene.(MONTHLY FEATURES)(European Community) | Law | Rainer, Anno, Renier, Philippe |
| Equity substitution loans in German commercial, insolvency and tax law: current status in anticipation of modernization. | Law | Kerssenbrock, Otto-Ferdinand |
| European Commission to investigate Spanish goodwill amortization on foreign shareholdings.(MONTHLY FEATURES)(EC Tax Scene) | Law | Rainer, Anno |
| European legal order with no mercy for member states' budget concerns. | Law | Thommes, Otmar |
| EVJ to answer further questions on Belgian dividend received deduction.(MONTHLY FEATURES)(EC Tax Scene) | Law | Rainer, Anno |
| Expected and unexpected developments of European integration in the field of direct taxes.(Editorial) | Law | Pistone, Pasquale |
| Exploring the boundaries of the application of Article 10(5) of the OECD Model.(Organisation for Economic Cooperation and Development) | Law | Madeira, Eduardo Arruda, Neves, Tiago Cassiano |
| Final Regulations issued on attributing E&P to stock of a foreign corporation.(earnings and profits) | Law | Tuerff, Tim, Trump, Christopher, Halpern, Irwin, Moneymaker, Dirk |
| Fiscal state aid goes global. | Law | Rossi-Maccanico, Pierpaolo |
| Flat-rate taxation based on cost-of-living expenditure - a profitable option for rich foreigners resident in Switzerland?(Report) | Law | Knirsch, D., Schanz, S. |
| Freedom of establishment in the EC economic partnership agreements: in search of its direct effect on direct taxation.(ARTICLES)(European Community)(Report) | Law | Bezborodov, Sergey |
| Governance, tax schemes, and big business. | Law | Ferrers, Tony |
| Group tax incentives under scrutiny: Dutch Interest box under investigation.(LEGISLATION)(THE NETHERLANDS) | Law | Weber, Dennis, Blokland, Gerard, Luja, Raymond |
| Improving the legitimacy of soft law in EU tax law.(European Union) | Law | Gribnau, Hans |
| Investor-state disputes: the interface between treaty-based international investment protection and fiscal sovereignty.(ARTICLES) | Law | Walde, Thomas, Kolo, Abba |
| Italian tax treaties and domestic law: some remarks about the relationship between provisions on foreign tax credit. | Law | Contrino, Angelo |
| Italy introduces rules on taxation of trusts.(LEGISLATION) | Law | Greco, Edward F. |
| Limitation of the temporal effects of judgments of the ECJ.(ARTICLES)(European Court of Justice) | Law | Lang, Michael |
| Limitation on Benefits: from the US Model 2006 to the ACT Group Litigation. | Law | Plansky, Patrick, Schneeweiss, Hermann |
| Multinationals, enforcement covenants and fair share. | Law | Happe, Richard |
| New German tax rules on financing expenses.(German 2008 Business Tax Reform) | Law | Scheunemann, Marc P., Muller-Duttine, Tino |
| Notable changes in the proposed indirect taxes through the Finance Bill 2007.(Finance Act in India) | Law | Govind, Har |
| Noteworthy fiscal and tax changes in India in the financial year 2006-07. | Law | Govind, Har |
| Preliminary questions referred to ECJ on Netherlands inheritance tax for non-residents.(CASE LAW)(THE NETHERLANDS)(European Court of Justice) | Law | Weber, Dennis, Blokland, Gerard |
| Proportionality of anti-avoidance and anti-abuse measures in the ECJ's direct tax case law.(measures for prevention of tax evasion and tax abuse under the direct tax case law of the European Court of Justice) | Law | Zalasinski, Adam |
| Proposal for a pension model with a compensating layer. | Law | Dietvorst, Gerry J.B. |
| Protocol to Canada treaty signed.(MONTHLY FEATURES)(US Tax Scene) | Law | Fuller, Thomas, Cohen, Harrison, Slaats, Sandra |
| Report on the conference: 'EU-taxes'.(CONFERENCE REPORT)(Vienna University of Economics and Business Administration) | Law | Heidenbauer, Sabine, Piscopo, Ramona |
| Safeguarding VAT revenue via actual cost taxation with collection at source.(value-added tax) | Law | Lohse, W. Christian, Gebauer, Andrea, Parsche, Rudiger |
| Some thoughts on further refinement of the concept of place of effective management for tax treaty purposes.(Report) | Law | Burgers, I.J.J. |
| Special commissioners withdraw reference to ECJ on CFC legislation.(European Court of Justice)(controlled foreign company) | Law | Tomsett, Eric |
| Taxation of cross-border savings: options for reviewing the European approach. | Law | Glaser, Lars |
| Taxation of non-profit organizations with multinational activities - the Stauffer Aftermath and tax treaties.(Centro di Musicologia Walter Stauffer Foundation) | Law | Ecker, Thomas |
| Taxes and the World Trade Organization.(ARTICLES)(Report) | Law | Rosembuj, Tulio |
| Tax facilities for state-induced costs under the EC state aid rules.(European Community) | Law | Hosson, Fred C. de |
| Tax treaties and the internal market in the new European scenario. | Law | Pistone, Pasquale |
| Tax treatment of non-operating companies in Italy. | Law | Santi, Alberto, La Candia, Ignazio |
| The Agreement on the Free Movement of Persons and its potential impact on direct taxes systems of EU member states.(European Union, Swiss Confederation) | Law | Adamczyk, Lukasz |
| The amendment of Australia's domestic law after the Lamesa case: a lesson to be learned from Dutch case law. | Law | Snoeij, Richard |
| The discriminatory taxation of permanent establishments by the host state in the European Union: a too much separate entity approach. | Law | Arginelli, Paolo |
| The effect of Community law on pre-accession tax treaties.(Articles)(European Community) | Law | Panayi, Christiana HJI |
| The effects of global and regional trade agreements on domestic tax law and bilateral tax conventions: proceedings of a seminar held at the 60th International Fiscal Association Congress. | Law | Farrell, Jennifer E. |
| The European Court of Justice on the Dutch Levy upon emigration of a substantial participation holder in a corporation. | Law | Kort, J.W.J. de |
| The Luxembourg Administrative Court lodges a reference for a preliminary ruling with the European Court of Justice concerning the taxation on non-resident individuals.(Case Law)(LUXEMBOURG) | Law | Elvinger, Andre, Richter, Dirk |
| The Masa Investment group as a "nec plus ultra" case for the application of the Europeam Convention on Human Rights to tax law?(Report) | Law | Greggi, Marco |
| The need for tax clarity and the application of the Acte Clair doctrine to direct taxes. | Law | Pistone, Pasquale |
| The new Italian provision on the fiscal residence of foreign companies - the legislator's haste and Tax Authorities' "distractions."(Legislation)(ITALY) | Law | Nanetti, Francesco, Mazzotti, Giulio |
| The OECD transfer pricing guidelines as a source of tax law: is globalization reaching the tax law?(Organization for Economic Cooperation and Development) | Law | Calderon, Jose |
| The procedural conditions for the implementation of tax treaty obligations under domestic law. | Law | Lang, Michael |
| The protection of human rights and the rigt to a fair tax trial in the light of the Jussila case.(ARTICLES) | Law | Greggi, Marco |
| The taxpayer's rights and the role of the Tax Ombudsman: an analysis from a Spanish and comparative law perspective.(comparison of tax ombudsmen's role in dispute resolution in Spain and Europe) | Law | Serrano, Fernando |
| Thin capitalization Glo et al. - a thinly concealed agenda.(interpretation of European tax laws by the European Court of Justice) | Law | Panayi, Christiana Hjl |
| Towards a more comprehensive examination of the compatibility of indirect taxes with the internal market. | Law | Sorensen, Karsten Engsig |
| Transfer pricing rules in the new Turkish Corporate Income Tax Act.(Report) | Law | Oner, Cihat |
| U.K. House of Lords rules compound interest applies to ACT compensation claims. | Law | Tomsett, Eric |
| US tax scene. | Law | Fuller, Thomas, Angle, Connie |
| US tax scene.(amendment of "foreign base company (FBC) services income" regulations) | Law | Cohen, Harrison, Tuerff, Tim, Danilack, Michael, Trump, Christopher |
| US tax scene: final portfolio interest exemption regulations released. | Law | Fuller, Thomas, Sina, Jeremy, Renfroe, Diane |
| US tax scene: new treaty and protocol with Belgium signed. | Law | Fuller, Tom, Van Hove, Pascal |
| US tax scene.(United States Treasury Department, Internal Revenue Services set rules) | Law | |
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