EUDTG Newsletter September – October 2015

EU direct tax law is a fast developing area. This presents taxpayers, in particular groups and multinational corporations that have an EU or European Economic Area (EEA) presence, with various opportunities.


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


CJEU Cases

  • Austria: CJEU Judgment on Austrian goodwill amortization: Finanzamt Linz
  • Netherlands: CJEU Judgment on discriminatory treatment of foreign shareholders receiving dividends from Dutch sources: Miljoen, X and Société Générale

National Developments

  • Finland: Proposed changes to domestic dividend taxation based on amendment to the EU Parent-Subsidiary Directive
  • Italy: New provisions on value attribution to assets of companies transferring place of residence to Italy
  • Italy: New provisions on horizontal tax consolidation
  • Italy: New branch exemption provisions
  • Spain: National High Court of Justice judgment on tax discrimination of UK UCITS
  • Spain: High Court of Justice of Madrid judgment on US investment funds
  • United Kingdom: First Tier Tribunal judgment about tax treatment of the statutory interest on repaid VAT
  • United Kingdom: 45% corporation tax on restitution interest

EU Developments

  • EU: EU-28 political agreement on automatic exchange of information of advance cross-border tax rulings and APAs
  • EU: European Commission launches public consultation on new proposal for CCCTB

Fiscal State aid

  • EU: European Commission final decisions on Starbucks Manufacturing BV and Fiat Finance and Trade
  • Spain: Amendment to General Tax Act regarding the State aid recovery procedure
  • Spain: Two High Court judgments on State aid regarding exemption from Spanish immovable property tax


Read the full newsletter here.


This EU Tax Newsletter is prepared by members of PwC’s international EU Direct Tax Group (EUDTG).

Further information about our service offerings in EU taxes:


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.