Opinion Statement ECJ-TF 4/2015 on the Decision of the European Court of Justice in Groupe Steria SCA (Case C-386/14) on the French Intégration Fiscale

in European Taxation (2016)

The Confédération Fiscale Européenne welcomes the Court’s clarification that cross-border company structures may not automatically be excluded from all the benefits of group taxation regimes but that ... [more ▼]

The Confédération Fiscale Européenne welcomes the Court’s clarification that cross-border company structures may not automatically be excluded from all the benefits of group taxation regimes but that rather, in general, a case-by-case assessment has to be made. This resolves concerns arising from the X Holding case, which, it is now clear, only addresses cross-border loss relief and perhaps tax-neutral intra-group transactions. [less ▲]