The European Curt of Justice ruled that the parent subsidiary directive, which exempts from withholding tax dividends paid from a EU subsidiary to a EU parent, does not apply to dividends paid to the holder of a usufruct right on the shares.
Continue Reading EU Parent-Subsidiary Directive Does Not Apply to Dividends on Shares Held in Usufruct, ECJ Ruled

AG of ECJ issued his opinion in Aberdeen Property Fininvest Alpha, according to which no withholding tax should apply to dividends to a EU company (in the case, a Luxembourg investment fund SICAV) if no similar tax applies to a domestic dividend
Continue Reading Withholding Tax on Outbound Dividends to a Luxemburg Investment SICAV Illegal, AG of the ECJ Says

The European Court of Justice with its decision in case C-285/07 held that the double carryover basis requirement imposed under German law to accord tax free treatment to the shareholders of the target corporation in a EU cross-border transfer of shares violates the EU mergers directive and EC law.
Continue Reading ECJ Ruled That Restriction to Tax-Free Treatment of Cross-Border Transfer of Shares is Illegal

European Court of Justice in Société Papillon (C-418/07) ruled that French national laws that limit access to tax consolidation in EU cross-border situations violate the EC Treaty. The ruling offers taxpayers opportunities to claim access to consolidation at the EU level every-time that such option is granted at domestic level and to offset losses and profits of the EU members of a consolidated group.
Continue Reading ECJ Ruled That Restrictions to Tax Consolidation Violate EC Treaty