Opinion Statement ECJ-TF 4/2013 of the CFE on the Decision of the European Court of Justice in Ettwein (Case C-425/11) : submitted to the European Institutions in December 2013

Resource Information

The work Opinion Statement ECJ-TF 4/2013 of the CFE on the Decision of the European Court of Justice in Ettwein (Case C-425/11) : submitted to the European Institutions in December 2013 represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Opinion Statement ECJ-TF 4/2013 of the CFE on the Decision of the European Court of Justice in Ettwein (Case C-425/11) : submitted to the European Institutions in December 2013

Creator

• CFE ECJ Task Force

Subject

• ECJ case law
• cross-border worker
• fundamental freedoms
• income splitting

Language

eng

Summary

This Opinion Statement analyses the decision of the European Court of Justice in Ettwein (case C-425/11), concerning a personal tax advantage for self-employed frontier workers under the EU-Switzerland Agreement on the free movement of persons (the Agreement). More specifically, Ettwein addresses the impact of the Agreement on the availability of the German splitting regime to Swiss residents who are German nationals and receive all their income in Germany. This regime aggregates the total income of the spouses, then notionally attributes 50% of it to each of them and taxes it accordingly. Therefore, if the income of one spouse is high and that of the other low, "splitting" levels out their taxable amounts and palliates the progressive nature of the income tax scales

Citation source

In: European taxation. - Amsterdam. - Vol. 54 (2014),

Geographic coverage

• European Union
• Europe

Language note

English