Opinion Statements

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. 


CFE Opinion Statement on Case C-464/14 Secil & the discriminatory treatment by Portugal of dividends received from third countries (ECJ-TF 1/2017)

The CFE ECJ Task Force has published an Opinion Statement on Case C-464/14, SECIL, in which the judgment of the 5th Chamber of the Court of Justice of the European Union (ECJ) was delivered on 24 November 2016. The Opinion Statement was submitted to the relevant European Institutions in February 2017. 

The case concerned the discriminatory Portuguese taxation of dividends received by corporate shareholders from their subsidiaries in third States, namely in Lebanon and Tunisia. In a clear and instructive judgment, the Court not only clarified the scope and impact of the Treaty provisions on free movement of capital but also the legal ramifications of the Euro-Mediterranean Agreements with Lebanon and Tunisia.

The Opinion Statement is available below. 



PDF icon ECJ-TF_1-2017_SECIL.pdf664.66 KB


CFE Opinion Statement ECJ-TF 2/2016 on the case Brisal & ors. and the admissibility of gross withholding taxation of interest

Opinion Statement ECJ-TF 2/2016 on the decision of the Court of Justice of the EU of 13 July 2016 in Case C-18/15, Brisal and KBC Finance Ireland, on the admissibility of gross withholding taxation of interest, has been prepared by the ECJ Task Force of the CFE and submitted to the European institutions in October 2016.

PDF icon ECJ TF 2-2016_Brisal.pdf529.38 KB