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During this course consequences of OECD BEPS in the EU will be discussed and other important new developments in EU Tax Law.

Detail Summary
Start date 22 October 2015
End date 23 October 2015
Time 09:00
ACTL seminar

The course will be held at the Ministry of Finance of the Slovak Republic and is open to a limited number of persons from outside the Ministry.

Subjects to be discussed:

  • the new EU GAAR in the parent-subsidiary directive (intragroup dividends) and in the Interest and Royalties directive
  • Forthcoming EU anti-BEPS directive
  • Minimum taxation in the EU anti-BEPS proposals
  • Abuse of Tax treaties – OECD Action 6
  • the EU abuse of tax law doctrine
  • Common (Consolidation) Corporate Tax Base (CCCTB)
  • CFC-legislation
  • Hybrid mismatches
  • Patent boxes (modified nexus approach)
  • Group taxation – per element approach ( Groupe Steria)
  • Cross-border losses and EU law (from Marks & Spencer to Commission/UK)
  • Tax Mismatches versus State Aid
  • Ruling and Advanced Transfer Pricing Agreements (APA) versus State Aid (Apple/Starbucks/FIAT/Amazon cases)
  • Withholding taxes and EU Law ( Miljoen)
  • Recent developments
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