Opinion Statements

CFE Opinion Statement FC 05/2017 regarding the VAT exemption of services provided by an independent group of persons (Article 132 (1) (f) of Directive 2006/112/EC)

On 1 March 2017 Advocate General Juliane Kokott delivered her Opinion in Case C‑605/15 Minister Finansów  v. Aviva Towarzystwo Ubezpieczeń na Życie S.A. w Warszawie.

The case concerned the scope of the VAT exemption commonly referred to as the "cost sharing associations exemption" in Article 132 (1) (f) of Directive 2006/112/EC. 

Due to the significance of this VAT exemption for many economic operators, the CFE considers that it is important to make a few technical comments on the position adopted by Advocate General Juliane Kokott.

We invite you to read our comments presented in the document below.  

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CFE Opinion Statement : Response to Consultation on the OECD BEPS Action 6 Public Discussion Draft on non-CIV examples

On 2 February 2017 the CFE Fiscal Committee submitted the folowing Opinion Statement in response to an OECD Public Consultation entitled: 

'Interaction between the tax treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds'

The Discussion Draft includes three draft examples with regard to the treaty entitlement of non-CIV Funds when applying the principle purpose test (hereinafter “PPT”) as described in the BEPS Action 6 final report. The CFE response provides comments on these three draft examples.

The CFE Response is available here.  

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CFE Opinion Statement on the EC consultation 'Effective Disincentives for Tax Advisers'

In respect of the European Commission public consultation 'Introducing Effective Disincentives for Advisors and Intermediaries of Potentially Aggressive Tax Planning Schemes', the CFE has adopted on 15 February 2017 a Joint Opinion Statement of its Fiscal and Professional Affairs Committees. The adopted Opinion Statement PAC/FC 1/2017, accompanies the remarks submitted on behalf of CFE to the European Commission questionnaire. 

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