The Resource Opinion Statement ECJ-TF 3/2018 on the ECJ decision of 12 June 2018 in Bevola (Case C-650/16), concerning the utilization of "definitive losses" attributable to a foreign permanent establishment

Opinion Statement ECJ-TF 3/2018 on the ECJ decision of 12 June 2018 in Bevola (Case C-650/16), concerning the utilization of "definitive losses" attributable to a foreign permanent establishment

Label
Opinion Statement ECJ-TF 3/2018 on the ECJ decision of 12 June 2018 in Bevola (Case C-650/16), concerning the utilization of "definitive losses" attributable to a foreign permanent establishment
Title
Opinion Statement ECJ-TF 3/2018 on the ECJ decision of 12 June 2018 in Bevola (Case C-650/16), concerning the utilization of "definitive losses" attributable to a foreign permanent establishment
Creator
Subject
Language
  • eng
  • eng
Summary
This CFE Opinion Statement, submitted to the European Institutions in November 2018, discusses the ECJ's decision in Bevola (Case C-650/16), which reaffirms that the concept of "definitive losses" first established in Marks & Spencer (Case C-446/03) and refined, inter alia, in Commission v. United Kingdom (Case C-172/13) is still applicable to permanent establishments and that the standard for testing comparability continues to be related to the aim pursued by the national provision at issue. Further, the CFE invites the EU to consider harmonizing measures that will introduce immediate loss utilization with a recapture mechanism
Citation source
In: European taxation. - Amsterdam. - Vol. 59 (2019), no. 2/3 ; p. 113-119
Geographic coverage
  • European Union
  • Europe
Language note
English
http://bibfra.me/vocab/lite/organizationName
CFE ECJ Task Force
http://library.link/vocab/subjectName
  • ECJ case law
  • PE
  • foreign company
  • comparability test
  • cross-border loss relief
  • justification
  • proportionality
  • ability to pay
Label
Opinion Statement ECJ-TF 3/2018 on the ECJ decision of 12 June 2018 in Bevola (Case C-650/16), concerning the utilization of "definitive losses" attributable to a foreign permanent establishment
Instantiates
Publication
Note
20190308
Other control number
et_2019_02_cfe_1.html
Label
Opinion Statement ECJ-TF 3/2018 on the ECJ decision of 12 June 2018 in Bevola (Case C-650/16), concerning the utilization of "definitive losses" attributable to a foreign permanent establishment
Publication
Note
20190308
Other control number
et_2019_02_cfe_1.html

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