A think tank dedicated to the study of tax law developments in the European Union, specifically related to direct taxation.

About the EU Tax Law Study Group

The EU Tax Law Study Group is a think tank dedicated to the study of tax law developments in the European Union, specifically related to direct taxation. Housed within IBFD’s European Knowledge Group, it is staffed by a team of specialists in EU tax law – direct taxation and supported by specialists in other EU topics of interest, including indirect taxation and transfer pricing.

Activities

The primary task of the EU Tax Law Study Group is to remain abreast of the evolving EU developments, and to ensure swift responses to these developments. The group's activities include:

conducting and facilitating research activities in the area of EU direct tax law
publishing articles, white papers, and statements on current EU tax law initiatives
monitoring, analysing and reporting on EU tax developments; and
contributing to expanding and strengthening of the product and service portfolio of IBFD.

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EU Tax Focus

This section provides updates on the progress in ongoing EU direct tax initiatives. Its objective is to serve as a specialized source, providing insights into the initiatives and uncovering their possible consequences. Additionally, it includes concise expert perspectives on the (implications of) other EU tax developments.

Scroll the EU Tax Focus notes below to stay updated on EU Tax developments and benefit from the perspective of our thought leaders.

Welcome Note - The Tax Wheel Is Spinning Fast

The EU Tax Law Study Group is delighted to introduce the EU Tax Focus, a space where we navigate the whirlwind of change and detangle the complexities of EU tax initiatives and developments.

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The “lost but not found” initiatives’ club: Unshell and others

Update created: 24 June 2024

Overall, in the last few months, countless articles have been written on “hot” tax topics. What happens, though, with all the initiatives which were once trending? Where do they stand, and should we expect them to progress any time soon? This note is intended to shed light to the “lost but not found” club of EU initiatives.

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A Framework for Taxation of Telework Income in the European Union: How Late?

Update created: 18 June 2024

Telework can create a tax hassle if work that can be performed anywhere in the world is not, in fact, performed within the same national borders in which the employer is located. This note describes the problem of taxation of telework income and observes the solutions that are being discussed at the EU level.

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FASTER, but softer: How the Council lowered the standards to make a quick match

Update created: 29 May 2024

The ECOFIN Council agreed on a general approach on a draft directive on Faster and Safer Relief of Excess Withholding Taxes (FASTER). This political match was only possible due to the increased flexibility guaranteed under the text prepared by the Belgian presidency of the Council. This note looks at the main differences from the initial proposal and at options available to Member States for the transposition of the Directive.

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Fugro v. Council: The story of a taxpayer “throwing down the glove” at the Minimum Taxation Directive

Update created: 28 May 2024

The present note wishes to bring the readers up to speed with the status of Fugro v. Council – a case in which the taxpayer requests the (partial) annulment of the Directive, arguing that the provisions whereby income from shipping activity is excluded from the computation of the qualifying income or loss of a constituent entity do not tie with EU (authorized) tonnage tax regimes.

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Through Thick and Thin: BEFIT under Scrutiny

Update created: 25 April 2024

The Business in Europe: Framework for Income Taxation (BEFIT) Directive belongs to the “triplets” of initiatives launched by the European Commission on 12 September 2023 (along with HOT and the TP Directive). Until now, EU institutions and stakeholders have seemed rather hesitant to engage in any tax technical discussions.

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Brief Overview of the ECJ Advocate General’s Opinion in the UK CFC Group Financing Exemption and a Trip Down Memory Lane, Revisiting Analogous State Aid Cases

Update created: 16 April 2024

According to the opinion of Advocate General (AG) Medina of the Court of Justice of the European Union (ECJ) (delivered on 12 April 2024), the European Commission and the General Court (GC) of the European Union erred in law when using the UK controlled foreign company (CFC) rules as reference framework for determining whether a selective advantage had been granted in the UK CFC Group Financing Exemption case – SA.44896 (summary here).

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Tax Simplification 101: HOT is Moving Forward

Update created: 15 April 2024

On 12 September 2023, the European Commission launched three proposals for Council Directives – the Business in Europe: Framework for Income Taxation (BEFIT) Directive, the Head Office Tax (HOT) Directive and a Transfer Pricing (TP) Directive. All three proposals are meant to simplify tax rules and provide certainty to EU businesses (the scope of the present note covers solely the HOT Directive).

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