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Opinion Statements

CFE opinion statement on the case law of the ECJ on Transfer Pricing related to Loans (C-311/08, SGI)

This is an opinion statement prepared by the ECJ TaskForce of the CFE on the case law of the European Court of Justice on transfer pricing related to loans (decision of 21 January 2010 in Case C-311/08, SGI).

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CFE Opinion Statement on ECJ transfer pricing case law re loans, SGI.pdf46.96 KB

CFE Opinion Statement on the Commentary on Art. 5 OECD Model (Permanent Establishment)

This is an opinion statement prepared by the Fiscal Committee of the CFE on proposed changes to the commentary on Article 5 of the OECD Model Tax Convention (Permanent Establishment). 

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CFE Opinion Statement, OECD Art5 PE.pdf61.06 KB

CFE Opinion Statement on the proposal for an EU Standardisation Regulation

This is an opinion statement prepared by the Professionnal Affairs Committee of the CFE on the Regulation proposal COM(2011)315 on European Standardisation.

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CFE Opinion Statement on the proposal for an EU Standardisation Regulation 24-1-2012.pdf156.88 KB

CFE Opinion Statement on the CCCTB proposal

This is an opinion statement prepared by the Fiscal Committee - Direct Tax Sub-Committee of the CFE on the proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB).

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CFE Opinion Statement on the CCCTB proposal.pdf172.23 KB

CFE Opinion Statement on Commission v Portugal

This is an opinion statement prepared by the ECJ TaskForce of the CFE on the decision of the European Court of Justice of 17 June 2010 in Case C-105/08, Commission v Portugal and the evidential requirements imposed by the ECJ in the context of infringement procedures.

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Commission v Portugal_C-105.08.pdf39.62 KB

CFE Opinion Statement on the Professional Qualifications Green Paper

This is an opinion statement prepared by the Professional Affairs Committee on the Professional Qualifications Green Paper.

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CFE Opinion Statement on the Professional Qualifications Green Paper.pdf224.71 KB

CFE Opinion statement on Haribo and Österreichische Salinen

This is an opinion statement prepared by the CFE ECJ TaskForce on the decision of the European Court of Justice of 10 February 2011 on the joined cases C-436/08 and C-437/08, Haribo and Österreichische Salinen and the tax treatment of inbound dividends in the EU and in relations with EEA and third countries.

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CFE Opinion Statement_Haribo and Österreichische Salinen.pdf69.8 KB

CFE Opinion Statement on the VAT Green Paper

The Opinion Statement is the response to the public consultation on the future of VAT (VAT Green Paper), conducted by the European Commission between December 2010 and May 2011. It has been prepared by the CFE Fiscal Committee.

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CFE Opinion Statement on the VAT Green Paper.pdf352.4 KB

CFE Opinion Statement on the right to an effective recovery of taxes levied in violation of EU law

This is an opinion statement prepared by the ECJ TaskForce on the interrelation between EU law and national procedural legislation in the area of direct taxation.

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CFE Opinion Statement on effective recovery.pdf85.92 KB

CFE response to consultation on dividends taxation

The reponse relates to the public consultation on taxation problems of cross-border dividends paid to individual or portfolio investors held by the European Commission in spring 2011. The paper refers to the CFE Opinion Statements on effective recovery and on the case Commission v. Italy (C-540/07) which can also be found on this website.

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CFE response, dividends taxation .pdf69.64 KB