ECJ clarifies rules on third country investments in FII GLO decision

November 21 2012

The European Court of Justice’s (ECJ) second judgment in the Franked Investment Income Group Litigation (FII GLO) clarifies when EU taxpayers can rely on free movement of capital for outward investments into non-EU jurisdictions. It also highlights the need for an answer regarding inward investment from non-EU taxpayers.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Request Access or Login

Topics

News European Union Tax Disputes Europe Jurisdictions United States (National) United Kingdom

more across site & shared bottom lb ros

More from across our site

Direct Tax

Hands of project managers discussing project management strategy

Beyond the headlines: Why advisers should think fast and slow in Budget season

Clients care more about considered counsel than rapid media-friendly soundbites, says Matthew Gilleard, associate director at Infinite

Matthew Gilleard, November 02 2026

Direct Tax

Deloitte dominates again at ITR Americas Tax Awards

It was also a memorable night for Galicia, KPMG, Skadden and Pinheiro Neto, all of which scooped major awards at a gala ceremony in New York

Sam Sholli, October 30 2026

London,,Uk,,Oct,10,,2026.,The,Offices,Of,Deloitte,At

A taxing week: (Richard) Houston, do we have a problem?

The former Deloitte UK CEO earned a 45% raise in a year when 1,000 staff reportedly lost their jobs – and the pay gap is only getting bigger

Ed Conlon, October 30 2026

Direct Tax

New York tax heavyweight Weil to wind down

In a seminal development for big law, the 95-year-old firm is set to cease operations after a series of high-profile partner departures

Tom Baker, October 29 2026

Direct Tax

‘Not for UK plc’: Budget prompts sceptical response from tax advisers

UK Chancellor John Healey extended a VAT cut, suspended tariffs, increased a bank surcharge and vowed to increase funding for HMRC

Sam Sholli, October 28 2026

Transfer Pricing

TP ‘matters more than ever’ under pillar two: Deloitte leader

Kristine Riisberg warned that TP decisions can determine top-up tax exposure under pillar two, while global consensus over the rules remains unsettled

Tom Baker, October 28 2026

Direct Tax

When cyber law becomes tax law

Both Germany’s NIS2 and the EU AI Act now determine whether a tax function can meet its obligations – and both can make management personally accountable

Christian Ewel, October 28 2026

Indirect Tax

European,Currency,Symbol,Euro,With,Green,Up,Arrow,On,Sticky

EU General Court narrows VAT exemption for credit management in securitisations

Originators, loan purchasers and securitisation vehicles may need to revisit servicing agreements and pricing after a key judgment narrowed the VAT credit management exemption

Florent Trouiller, October 27 2026