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:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: AI is reshaping capital flows and toppling the old tax order

Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created

Teresa Owusu-Adjei, March 20 2026

Direct Tax

This week in tax: KPMG announces Gary Wingrove as new global chairman and CEO

Wingrove will succeed Bill Thomas, who has served in the role since 2017; in other news, Andersen unveiled a sharp increase in revenues for 2025

Sam Sholli, March 20 2026

Transfer Pricing

‘Clear limitations’: Italian advisers differ on intra-group financing TP ruling

Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases

Sam Sholli, March 19 2026

Direct Tax

Back office to backbone: tax risks of evolving global capability centres

As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management

Mehul Jain, March 19 2026

Direct Tax

‘Kept the family together’: EU tax chief praises US/OECD pillar two deal

While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’

Sam Sholli, March 18 2026

Direct Tax

The pillar two side-by-side agreement: key questions answered

From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal

Russell Gammon, March 17 2026

Direct Tax

Tax campaigners clash on pillar two as side-by-side deal costs emerge

Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’

Sam Sholli, March 16 2026

Direct Tax

A taxing week: WTS enters fierce battle for global tax advisory supremacy

The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player

Tom Baker, March 13 2026

Direct Tax

London- HM Revenue and Customs building on Whitehall, UK Governm

This week in tax: HMRC defers tax agent registration for financial services businesses

The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions

Sam Sholli, March 13 2026

Transfer Pricing

HMRC almost doubles revenue from TP cases in one year

Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed

Sam Sholli, March 12 2026