EUDTG Newsletter 2015 – nr. 003 (March – April 2015)

This EU Tax Newsletter is prepared by members of PwC’s international EU Direct Tax Group (EUDTG). If you would like to receive future editions of this newsletter, or wish to read previous editions, please refer to:


The following topics are covered in this issue of EU Tax News:

1. EU Court of Justice (CJEU) Cases

  • Austria: AG Opinion on Austrian goodwill amortisation scheme: Finanzamt Linz
  • Germany: Judgment on German roll-over relief where acquired or manufactured assets belong to a German PE’s capital assets: Commission v. Germany
  • Germany: CJEU Referral on tax relief in the case of multiple inheritances or gifts of the same assets: Feilen
  • Germany: AG Opinion on the link between Art. 4(4) German-Swiss double tax treaty and the EU-Swiss agreement on the free movement of persons: Bukovansky
  • Italy: CJEU Order on cumulative application of administrative penalties and criminal charges: Burzio

2. National Developments

  • Belgium: New draft bill on the contribution of financial institutions to State revenue
  • Belgium: Draft Cayman Tax bill: tax transparency for ‘legal constructions’
  • Belgium: Recent developments with respect to Belgian Fokus Bank claims for funds
  • Greece: Significant procedural requirements introduced for the deductibility of corporate expenses
  • Netherlands: Dutch AG opines that Luxembourg SICAV is not entitled to a refund of Dutch dividend withholding tax

3. EU Developments

  • EU: European Commission presents “Tax Transparency Package”, including mandatory automatic exchange of cross-border tax rulings in the EU
  • EU: European Parliament adopts Resolution on Annual Tax
  • Belgium: European Commission requests Belgium to bring its rules on dividend taxation into line
  • France: European Commission launches infringement procedure over 3% contribution on distribution of profits
  • Switzerland: EU and Switzerland agree to automatic exchange of information in tax matters from September 2018

Read the full newsletter here.

Should you have any questions, please contact your usual PwC contact or me.

Published by

Armin Marti

Armin Marti

Armin Marti
Birchstrasse 160
Postfach, 8050 Zurich
+41 58 792 43 43

Armin leads the PwC Swiss Tax Policy efforts. He holds a Master in Business Administration from the University of St. Gallen, Switzerland (lic. oec. HSG) and has qualified as a Swiss Certified Tax Expert. As a member of the global PwC International Tax Services (ITS) Network and former Swiss corporate tax leader, ITS leader and Transfer Pricing Leader, Armin has gained extensive experience in leading complex cross-border tax projects. Armin Marti has over 30 years experience in providing international tax consultancy for large quoted and privately held Swiss and foreign multinationals. He advises his clients in international tax, transfer pricing, tax policy and tax strategy matters, including domestic and cross-border tax restructurings, acquisitions and divestments, effective supply chain and business models.