References of "Richelle, Isabelle"
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See detailProcedural Law in Tax Law – Belgian Report
Richelle, Isabelle ULiege

in Procedural Law in Tax Law (in press)

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See detailOpinion 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"
Richelle, Isabelle ULiege

in European Taxation (2019), february/march

"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 ... [more ▼]

"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". [less ▲]

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See detailThe Tax Dispute Resolution Directive
Richelle, Isabelle ULiege

Conference given outside the academic context (2019)

Presentation and evaluation of the new tax dispute resolution mechanism introduced by the EU Directive 2017/1852 on tax dispute resolution

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See detailOpinion Statement ECJ-TF 2/2018 on the ECJ Decision of 7 Sept. 2017 in Eqiom (Case C-6/16), Concerning the Compatibiloity of the French Anti-Abuse Rule Regarding outbound Dividends with the EU Parent-Subsidiary Directive (2011/96) and the Fundamental Freedoms
Richelle, Isabelle ULiege

in European Taxation (2018)

"This CFE OS, submitted to the EU Institutions in May 2018, addresses the ECJ's decision in Eqiom (Case C-6/2016), which concerns the EU law compatibility of the French anti-abuse rule regarding outbound ... [more ▼]

"This CFE OS, submitted to the EU Institutions in May 2018, addresses the ECJ's decision in Eqiom (Case C-6/2016), which concerns the EU law compatibility of the French anti-abuse rule regarding outbound dividends" [less ▲]

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See detailOpinion Statement ECJ-TF 1/2018 on the Decision of the Comptability of Limitation-on-Benefits Clauses with the EU Fundamental Freedoms
Richelle, Isabelle ULiege

in European Taxation (2018)

"This OS was prepared by the CFE Task Force and concerns the compatibility of LoB clauses with the EU fundamental freedoms, based on decisions of the ECJ. The context of this statement is the Commission's ... [more ▼]

"This OS was prepared by the CFE Task Force and concerns the compatibility of LoB clauses with the EU fundamental freedoms, based on decisions of the ECJ. The context of this statement is the Commission's infringement procedure against the Netherlands with regard to the LB clause in the Japan-Netherlands Income Tax Treaty (2010) and the inclusion of a simplified optional LoB clause in the BEPS Multilateral Instrument" [less ▲]

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See detailDans les arcanes de la nouvelle directive sur le règlement des différends fiscaux
Richelle, Isabelle ULiege

in Paschalidis, Paschalis; Wildemeersch, Jonathan (Eds.) L’Europe au présent ! - Liber amicorum Melchior Wathelet (2018)

In-depth analysis of the EU Directive on Tax Dispute Resolution

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See detailSelection of the arbitrators under the Arbitration Convention and Dispute Resolution Directive
Richelle, Isabelle ULiege; Peeters, Bart ULiege

Conference (2018, July)

Selection of the arbitrators under the Arbitration Convention and Dispute Resolution Directive: analysis and comments on how arbitrators are to be chosen

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See detailLa réforme de l'impôt des sociétés - Questions choisies
Richelle, Isabelle ULiege

Scientific conference (2018, April 28)

Introduction : les objectifs de la réforme 2017 La modification des taux et mesures diverses Mesures diverses 1ère opération 2ème et 3ème opérations - Ventilation et compensation horizontale des pertes ... [more ▼]

Introduction : les objectifs de la réforme 2017 La modification des taux et mesures diverses Mesures diverses 1ère opération 2ème et 3ème opérations - Ventilation et compensation horizontale des pertes 4ème opération - RDT 5ème opération - Déduction pour revenus d’innovation 6ème opération - NID: incrémentaux 7ème opération – Report vertical des pertes 8ème opération - Déduction pour investissement 9ième opération - Report de NID Consolidation fiscale Règles « CFC » Corbeille Notion d’établissement stable Entrée en vigueur [less ▲]

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See detailOpinion Statement ECJ-TF 4/2017 on the Decision of the Court of Justice of the European Union of 9 February 2017 in X (Case “Pro-Rata Personal Deductions”), Concerning Personal and Family Tax Benefits in Multi-State Situations
CFE ECJ Task Force; Richelle, Isabelle ULiege

in European Taxation (2018)

This Opinion Statement was prepared by the CFE ECJ Task Force. It concerns X (Case C-283/15), in respect of which the First Chamber of the Court of Justice of the European Union (ECJ) delivered its ... [more ▼]

This Opinion Statement was prepared by the CFE ECJ Task Force. It concerns X (Case C-283/15), in respect of which the First Chamber of the Court of Justice of the European Union (ECJ) delivered its decision on 9 February 2017. In general terms, the Court followed the Opinion of Advocate General Wathelet of 7 September 2016. [less ▲]

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See detailLa réforme de l'impôt des sociétés - Questions choisies
Richelle, Isabelle ULiege

Scientific conference (2018, March 06)

I. Introduction : les objectifs de la réforme 2017 II. La modification des taux et mesures diverses III. Mesures diverses IV. 1ère opération V. 2ème 3ème opérations -Ventilation et compensation ... [more ▼]

I. Introduction : les objectifs de la réforme 2017 II. La modification des taux et mesures diverses III. Mesures diverses IV. 1ère opération V. 2ème 3ème opérations -Ventilation et compensation horizontale des pertes VI. 4ème opération - RDT VII. 5ème opération - Déduction pour revenus d’innovation VIII. 6ème opération - NID : incrémentaux [less ▲]

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See detailOpinion Statement ECJ-TF 4/2017 on the Decision of the Court of Justice of the European Union of 9 February 2017 in X (Case C-283/15) (“pro-rata personal deductions”), concerning personal and family tax benefits in multistate situations
CFE ECJ Task Force; Richelle, Isabelle ULiege

in European Taxation (2018), 58(2018), 163-169

This CFE Opinion Statement, submitted to the European Institutions in December 2017, comments on the ECJ decision in X (Case C-283/15) (“pro-rata personal deductions”) Concerning personal and family tax ... [more ▼]

This CFE Opinion Statement, submitted to the European Institutions in December 2017, comments on the ECJ decision in X (Case C-283/15) (“pro-rata personal deductions”) Concerning personal and family tax benefits in multi state situations [less ▲]

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See detailLes aspects internationaux de la réforme de l'impôt des sociétés
Richelle, Isabelle ULiege

Scientific conference (2018, February 01)

1.Notion d’établissement stable 2.Compensation des pertes 3.«Consolidation fiscale» Nouvelle [5ème] opération -Déduction de la contribution de groupe 4.Nouvelles règles «CFC» 5.Exit Tax

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See detailBelgium: Transparent Entities: The Case of the French SCI under the Belgium-French Tax Treaty
Richelle, Isabelle ULiege

in Lang, Michaël; Rust, Alexander; Owens, Jeffrey (Eds.) et al Tax Treaty Case Law around the Globe 2017 (2018)

This book is a unique publication that gives a global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 41 most ... [more ▼]

This book is a unique publication that gives a global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 41 most important tax treaty cases that were decided around the world in 2016. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2017 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics. [less ▲]

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See detailOpinion Statement ECJ-TF 3/2017 on the Decision of the Court of Justice of the European Union of 16 May 2017 in Berlioz Investment Fund SA (Case C-682/15), Concerning the Right to Judicial Review under Article 47 of the EU Charter of Fundamental Rights in Cases of Cross-Border Mutual Assistance in Tax Matters
CFE ECJ Task Force; Richelle, Isabelle ULiege

in European Taxation (2018), 58(2018), 23

Berlioz Investment Fund SA (Case C-682/15), Concerning the Right to Judicial Review under Article 47 of the EU Charter of Fundamental Rights in Cases of Cross-Border Mutual Assistance in Tax Matters

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See detail“Transparent Entities: The Case of the French SCI under the Belgium-French Tax Treaty”
Richelle, Isabelle ULiege

in Lang et al. (Ed.) Tax Treaty Case-Law around the globle 2017 (2018)

commentary on a recent judgment of the Belgian Supreme Court, devoting a reversal of jurisprudence, concerning the taxation in Belgium of the income generated by a "real estate company" under French law ... [more ▼]

commentary on a recent judgment of the Belgian Supreme Court, devoting a reversal of jurisprudence, concerning the taxation in Belgium of the income generated by a "real estate company" under French law, subject in France to a regime of "translucency" [less ▲]

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See detailActualités en fiscalitéeuropéenne et internationale: impact international de la future réforme de l'ISOC en Belgique
Richelle, Isabelle ULiege; Van de Velden, Kim

Scientific conference (2017, December 04)

First comments on the corporate tax reform project, in an international and european perspective.

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See detailThe Impact of Bilateral Investment Treaties on Taxation - Belgian Report
Richelle, Isabelle ULiege; Traversa, Edoardo

in Lang, Michael; Owens, Jeffrey; Pistone, Pasquale (Eds.) et al The Impact of Bilateral Investment Treaties on Taxation (2017)

The tax aspects of bilateral investment treaties, which, in most cases, provide the investor with the unique opportunity to directly initiate an international dispute settlement process – also known as ... [more ▼]

The tax aspects of bilateral investment treaties, which, in most cases, provide the investor with the unique opportunity to directly initiate an international dispute settlement process – also known as investor-state dispute settlement – are often overlooked. The increasing number of tax-related investment disputes is a clear indicator of an urgent need to identify and examine the issues emerging in this area in an academic context. The aim of this book is to provide a comprehensive analysis of the relationship between taxation and bilateral investment treaties. Twenty-one national reports from countries across the globe have been compiled in this volume. The reports, prepared for the conference “The Impact of Bilateral Investment Treaties on Taxation”, which took place in Rust (Austria) from 2-4 July 2015, help bring to light tax aspects of bilateral investment treaties that have significant unexplored aspects. Tax academics and tax practitioners, along with investment law academics and practitioners, provided their input. A major focus is the attitude taken towards tax matters in the bilateral investment treaties of reporting countries, as is the relationship between double tax treaties and bilateral investment treaties. In addition to the national aspects, the book also outlines global trends and best practices, and in doing so it aims to analyse the consistency of existing policies with the international obligations undertaken in bilateral investment treaties. The general report elaborates extensively on issues connected with tax carve-out provisions in bilateral investment treaties and the arbitration of tax matters. This book is of relevance to practitioners and academics working in tax law and international investment law, as well as students doing research and all who have an interest in the most current issues in these fields of law. [less ▲]

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See detailOpinion Statement ECJ-TF 2/2017 on the ECJ Decision of 21 December 2016 in World Duty Free Group and Others (Joined Cases C-20/15 P and C-21/15 P), Concerning the Requirements of Selective Aid in the Sense of Article 107 of the TFEU
CFE ECJ task Force; Richelle, Isabelle ULiege

in European Taxation (2017), (2017), 354-357

This CFE Opinion Statement, submitted to the European Institutions on 29 June 2017, discusses World Duty Free Group (formerly Autogrill España); Banco Santander and Santusa Holding (Joined Cases C-20/15 P ... [more ▼]

This CFE Opinion Statement, submitted to the European Institutions on 29 June 2017, discusses World Duty Free Group (formerly Autogrill España); Banco Santander and Santusa Holding (Joined Cases C-20/15 P and C-21/15 P), wherein the ECJ held that that an aid can be regarded as selective if the national tax measure deviates from the reference framework: it is not necessary to show that the national tax measure actually favours a specific group of undertakings or the production of specific goods. [less ▲]

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See detailActualités fiscales européennes - impôts directs
Richelle, Isabelle ULiege

Scientific conference (2017, June 12)

Actualités en matière de fiscalité européenne - 2016/2017 - Conférence donnée avec Prof. E. Traversa et M. Giffoni

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See detailOpinion Statement ECJ-TF 1/2017 on the Decision of the Court of Justice of the European Union in SECIL (Case C-464/14) Concerning the Free Movement of Capital and Third Countries
CFE ECJ task Force; Richelle, Isabelle ULiege

in European Taxation (2017), (2017), 163-172

This is an Opinion Statement prepared by the CFE ECJ Task Force on SECIL (Case C-464/14), in which the 5th Chamber of the Court of Justice of the European Union (ECJ) delivered its decision on 24 November ... [more ▼]

This is an Opinion Statement prepared by the CFE ECJ Task Force on SECIL (Case C-464/14), in which the 5th Chamber of the Court of Justice of the European Union (ECJ) delivered its decision on 24 November 2016,1 following the Opinion of Advocate General Wathelet of 27 January 2016.2 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 decision, the Court not only clarified the scope and impact of the Treaty provisions on the free movement of capital, but also the legal ramifications of the Euro- Mediterranean Agreements with Lebanon and Tunisia. [less ▲]

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