June 2013 - edition 118EU Tax Alert

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Highlights in this editionEuropean Court of Human Rights finds Hungarian tax rules to be in breach of the European Convention on Human Rights (N.K.M. v Republic of Hungary)The European Court of Human Rights delivered its judgement in case N.K.M. v Republic of Hungary. The case dealt with the Hungarian rules which impose a 98% tax on the upper bracket of severance payments for employees dismissed from the public sector. The European Court of Human Rights considered that such legislation violates Article 1 of Protocol 1 of the Convention as it constitutes an unjustified deprivation of property.

CJ rules that deduction of VAT may in principle be refused in case of incomplete invoices (Petroma Transports SA)The CJ delivered its judgement in case C-271/12 Petroma Transports SA. The CJ ruled that Member States may in principle refuse the deduction of VAT if taxable persons, as recipient of services, exercise their right to deduct based on invoices which are incomplete. According to the CJ, this also applies if the invoices are corrected after the decision to refuse the right to deduct has been adopted.

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ContentsTop News• ECHR finds Hungarian legislation providing for a

98% tax over payments to employees of the public

sector for termination of employment in breach of

the right to private property (N.K.M. v Republic of

Hungary)

• CJ rules that deduction of VAT may in principle be

refused in case of incomplete invoices (Petroma

Transport SA)

State Aid / WTO• Recovery of benefit from Irish differential air travel

tax rate ordered

Direct taxation• ECOFIN and Council of the EU discuss

amendments to the Savings Directive and measures

against tax evasion and tax fraud

• EFTA Surveillance Authority decides to bring Iceland

before the EFTA Court for taxing companies on

unrealised capital gains on cross-border mergers

• Commission refers France to the CJ regarding

discriminatory property tax rules

VAT• CJ rules on basis of assessment for assets held

after cessation of taxable activities (Hristomir

Marinov)

• CJ rules on Polish provision on how to establish the

time a company becomes liable to pay VAT (TNT

Express Worldwide)

• CJ clarifies rules on repayment of input VAT for

which the deduction was prevented in breach of EU

VAT law (Alakor)

• Commission notice on test case for private VAT

rulings

• Commission communication on request for

derogating measure for Germany

Customs Duties, Excises and other Indirect Taxes• Commission meets experts on customs controls of

trans-boundary waste shipments

• Discussion on EPA implementation with the Eastern

and Southern African partners

• Commission reports on its successes in defending

EU exports

• Launch of anti-subsidy investigation on solar glass

from China

• The European Commission ready for an ex officio

trade defence action against Chinese mobile

telecommunications equipment

4 5

‘Every natural or legal person is entitled to the peaceful

enjoyment of his possessions. No one shall be deprived

of his possessions except in the public interest and

subject to the conditions provided for by law and by the

general principles of international law.

The preceding provisions shall not, however, in any

way impair the right of a State to enforce such laws as

it deems necessary to control the use of property in

accordance with the general interest or to secure the

payment of taxes or other contributions or penalties.’

The ECHR went on to analyse the several elements

of Article 1 of Protocol 1. It first started by analysing

whether the severance pay received constituted

‘possessions’ within the meaning of the referred Article,

as Ms N.K.M. had actually never possessed the entire

payment in question since the special tax applicable

had been directly withheld by the tax authorities. The

ECHR observed that the concept of ‘possessions’ in

the first paragraph of Article 1 of Protocol No. 1 has

an autonomous meaning which is not limited to the

ownership of material goods and is independent from

the formal classification in domestic law. It stated that

‘possessions’ within the meaning of Article 1 of Protocol

No. 1 can be either ‘existing possessions’ or assets,

including claims, in respect of which an applicant can

argue that he has at least a ‘legitimate expectation’

that they will be realised. Thus, it considered that a

‘legitimate expectation’ of obtaining an asset may also

enjoy the protection of Article 1 of Protocol No. 1.

The second element analysed by the ECHR was

whether there was an interference with the possessions

of the individual. It concluded that a legislative

amendment which removes a legitimate expectation

may amount in its own right to an interference with

‘possessions’. In other words, the taxation at stake

represented an interference with the right to peaceful

enjoyment of possessions by Ms N.K.M.

The third element was whether such public interference

was lawful. The ECHR started by recalling that Article

1 of Protocol No. 1 requires that any interference

by a public authority with the peaceful enjoyment of

possessions should be lawful: indeed, the second

Top NewsECHR finds Hungarian legislation providing for a 98% tax over payments to employees of the public sector for termination of employment in breach of the right to private property (N.K.M. v Republic of Hungary)On 14 May 2013, the European Court of Human Rights

(ECHR) issued its judgment in case N.K.M. v Republic

of Hungary (application no. 66529/11). The case refers

to the Hungarian rules which impose a 98% tax on the

upper bracket of severance payments for employees

dismissed from the public sector.

Ms N.K.M. was a civil servant for thirty years. On May

2011, she was dismissed with effect from 28 July 2011.

On dismissal, she received two months’ salary for June

and July 2011, during which time she was exempted

from work. In addition, she was to receive severance

pay amounting to eight months’ salary as well as to

an unspecified sum corresponding to unused leave

of absence. Those benefits were subsequently taxed

at 98% in their part exceeding 3.5 million Hungarian

forints. This represented an overall tax burden of

approximately 52% on the entirety of the severance, as

opposed to the general personal income tax rate of 16%

in the relevant period.

Ms N.K.M. complained under Article 1 of Protocol No. 1

- read alone and in conjunction with Article 13 - that

the imposition of a 98% tax on the upper bracket of

her severance constituted an unjustified deprivation

of property, or else taxation at an excessively

disproportionate rate, with no remedy available. She

also considered that Article 14 of the Convention read in

conjunction Article 1 of Protocol No. 1 had been violated

because only those dismissed from the public sector

were subjected to the tax and because a preferential

threshold was applicable to only a group of those

concerned.

Article 1 of Protocol no. 1 of the Convention provides

that:

5

time of economic hardship, the ECHR noted that the

majority of citizens were not obliged to contribute, to a

comparable extent, to the public burden.

It further noted that Ms. N.K.M. had to suffer a

substantial deprivation of income in a period of

considerable personal difficulty, namely that of

unemployment. In this regard, it was relevant for

the ECHR that the tax was directly deducted by the

employer from the severance without any individualised

assessment of the Ms N.K.M. situation. In addition, the

ECHR recalled that the tax was determined in a statute

that had been enacted and entered into force some

ten weeks before the termination of the civil service

relationship, and it was not intended to remedy technical

deficiencies of the pre-existing law, nor had Ms N.K.M.

enjoyed the benefit of a windfall in a changeover to a

new tax-payment regime. All these elements considered

led the ECHR to conclude that there was a violation of

Article 1 of Protocol no. 1 of the Convention.

CJ rules that deduction of VAT may in principle be refused in case of incomplete invoices (Petroma Transport SA)On 8 May 2013, the CJ delivered its judgment in case

C-271/12. The case concerns a Belgian group of

companies, ‘the Martens Group’. Petroma Transports

SA (‘Petroma’) was the main company in the Martens

Group in terms of staff and provided numerous services

to other companies within that group. For the intra-group

services, Petroma received remuneration on the basis of

hours worked by the staff.

The Belgian tax authorities questioned the intercompany

invoices and resulting deductions of input VAT, because

the invoices were incomplete and could not be shown

to correspond to actual services. Most invoices included

an overall amount with no indication of unit price or

hours worked by the staff. As a consequence, the

tax authorities denied the deductions of input VAT.

Subsequently, Petroma provided additional information,

but the tax authorities took the position that this

information lacked any probative value.

sentence of the first paragraph of that Article authorises

the deprivation of possessions ‘subject to the conditions

provided for by law’. However, the existence of a

legal basis in domestic law does not suffice, in itself,

to satisfy the principle of lawfulness. In addition, the

legal basis must have a certain quality, namely it must

be compatible with the rule of law and must provide

guarantees against arbitrariness. However, in what

refers to taxation, the ECHR referred to its previous

case law in order to consider that some degree of

additional deference and latitude in the exercise of their

fiscal functions under the lawfulness test.

The fourth element under the ECHR scrutiny was

whether there was an exception of public interest that

could justify the tax measure at stake. The ECHR

started by observing that while the impugned measure

was intended to protect the public purse against

excessive severance payments, it was not convinced

that this goal was primarily served by taxation. There

was a possibility to change severance rules and reduce

the amounts which were contrary to public interest,

but the authorities did not opt for this course of action.

However, it was of the view that it was not necessary

to decide on the adequacy of a measure that formally

serves a social goal, since this measure is in any event

subject to the proportionality test.

Finally as regards the proportionality test, the ECHR

analysed whether a ‘fair balance’ between the

demands of the general interest of the community and

the requirements of the protection of the individual’s

fundamental rights. The ECHR referred to the fact that

the tax rate applied exceeds considerably the rate

applicable to all other revenues, including severance

paid in the private sector, without determining

in abstracto whether or not the tax burden was,

quantitatively speaking, confiscatory in nature.

According to the ECHR, this entailed an excessive and

individual burden to Ms N.K.M.. This is all the more

evident when considering the fact that the measure

targeted only a certain group of individuals, who were

apparently singled out by the public administration in

its capacity as employer. Assuming that the impugned

measure served the interest of the State budget at a

6 7

lower rate were mainly operated by a few operators with

close links to Ireland. Despite the fact that the tax would

be passed on to individual consumers, the Commission

found that the operators still profited by being able to

sell short-route tickets at a lower price.

The Commission hence ordered the recovery of the

difference in rate of EUR 8 per passenger from at least

three Irish airlines and potentially others to be identified

by the Irish government. This order relates to the 2009-

2011 timeframe and it is provided that interest is due as

well. Should any aid fall within the scope of the block

exemption regulation or the de minimis regulation, it

would not have to be recovered. This is left for the Irish

authorities to determine. (The order dates from 25 July

2012, but the detailed decision was only released to the

public recently on 30 April 2013. Appeals were filed in

November 2012.)

Direct TaxationECOFIN and Council of the EU discuss amendments to the Savings Directive and measures against tax evasion and tax fraudOn 14 May and 22 May 2013, the European Council

and the Council of the European Union held meetings

(respectively) in which they discussed possible

amendments to Directive 2003/48/EC on the taxation

of savings income as well as possible measures to fight

tax evasion and tax fraud.

It was approved to mandate the Commission to

negotiate amendments to the EU’s agreements with

Switzerland, Liechtenstein, Monaco, Andorra and San

Marino on the taxation of savings income. The aim is to

ensure that these five countries will continue to apply

measures that are equivalent to the EU’s directive on

the taxation of savings income which is being amended.

The amendments to the Directive include enlarging

its scope to include all types of savings income, as

well as products that generate interest or equivalent

income and at providing a look-through approach for the

identification of beneficial owners.

Eventually the case was brought before the Court of

Appeal, which decided to refer questions to the CJ. The

referring court in essence wanted to know whether the

right to deduct VAT could be refused because of the fact

that the invoices were incomplete, if those invoices were

supplemented afterwards to prove occurrence, nature

and amount of the transactions invoiced.

The CJ ruled that Member States may, in principle,

refuse the deduction of VAT if taxable persons, as

recipients of services, exercise that right to deduct

based on invoices which are incomplete. According to

the CJ, this also applies if the invoices are corrected

after the decision to refuse the right to deduct has been

adopted. Moreover, the CJ ruled that the principal of

fiscal neutrality in such circumstances does not have

a bearing on this conclusion, as the VAT was due and

correctly remitted to the tax authorities.

State Aid/WTORecovery of benefit from Irish differential air travel tax rate orderedIn March 2009, Ireland introduced an air travel tax with

a general rate of EUR 10 per departing passenger (on

an aircraft capable of carrying at least 20 persons).

A lowered EUR 2 rate was available for flights from

an Irish airport to any destination within 300 km from

Dublin airport. This tax was replaced in March 2011 by

a uniform EUR 3 rate after a Commission investigation

into possible infringements of the freedom of services

and of an EU regulation on the operation of air services.

After a formal State aid investigation into the lower rate

that was enacted from 2009 to 2011, the Commission

found the lower rate to amount to unlawful State aid.

The Commission considered, amongst others, that a

lower rate could not be justified on the basis of distance

as it was not the actual distance from a particular airport

but the distance of the destination from Dublin that was

leading. Moreover, the departure from an Irish airport

was the taxable event for the tax, as a result of which

the distance criterion mainly favoured national flights.

The Commission found that the flights eligible for the

7

provided in the EEA Agreement as they render it less

attractive for companies to make use of their right to

establish themselves in other EEA States.

The Authority does not contest that Iceland may

protect its right to tax gains accrued while a company

was established in Iceland. However, it considers that

Iceland should apply less restrictive measures to protect

this right such as offering companies the possibility of

deferring their payment of the tax.

Commission refers France to the CJ regarding discriminatory property tax rulesOn 30 May 2013, the European Commission decided

to refer France to the CJ concerning its discriminatory

tax rules on new residential property. French rules allow

investments in new residential property in France, which

is intended for letting for a minimum of nine years, to

benefit from accelerated depreciation, whereas such

benefit is not available for similar investments made

abroad. This results in a more favourable tax treatment

for French investments vis-à-vis foreign investments

as taxpayers investing the same amount in immovable

goods abroad would face a higher tax liability.

The Commission considers such provisions

incompatible with the free movement of capital.

VAT CJ rules on basis of assessment for assets held after cessation of taxable activities (Hristomir Marinov) On 8 May 2013, the CJ delivered its judgment in case

C-142/12. The case concerns the non-compliance by

Mr. Hristomir Marinov (‘Marinov’) of his VAT obligations.

In particular, he did not pay the amount of VAT due

based on the VAT declarations. As a result, the

Bulgarian tax authorities removed Mr. Marinov from the

VAT register. The tax authorities also indicated that VAT

was due on some road vehicles, which had been hired

by Mr. Marinov under leasing contracts and for which

he had deducted VAT on each lease. The tax authorities

Regarding the need to combat tax fraud and tax

evasion as well as aggressive tax planning, there is a

recognition that appropriate measures should be taken

at national, EU, and global levels. In this context, there

is increasing support for further efforts on the adoption

of automatic exchange of information and on improving

the implementation and enforcement of standards

of beneficial ownership information relevant for tax

purposes. Both the ECOFIN and the Council of the EU

also support the efforts at the OECD level on the work

on Base Erosion and Profit Shifting. At the level of the

EU institutions, further work will be carried forward by

the Commission on recommendations on aggressive

tax planning and profit shifting. In that regard, the

Commission intends to present a proposal before the

end of the year for the revision of Directive on Council

Directive 2011/96/EU of 30 November 2011 (Parent/

Subsidiary Directive) as is reviewing the anti-abuse

provisions in the relevant EU legislation.

The Council of the EU called upon Member States

to consider whether their current legislation includes

(or may include) a general anti-avoidance rule which

is effective against abusive tax arrangements and in

compliance with the EU Treaties.

EFTA Surveillance Authority decides to bring Iceland before the EFTA Court for taxing companies on unrealised capital gains on cross-border mergers On 29 May 2013, the EFTA Surveillance Authority

decided to bring Iceland before the EFTA Court for

taxing companies on unrealised capital gains when they

carry out cross-border mergers. According to Icelandic

domestic tax legislation, companies in Iceland that

undertake cross-border mergers within the EEA are

required to pay tax on all capital gains relating to their

assets and shares upon the moment they exit Iceland,

even though these gains have not been realised.

Contrary to this, Icelandic companies merging with other

companies within Iceland are under no such obligation.

The EFTA Surveillance Authority is of the view that

those rules constitute a breach to the freedom of

establishment and the free movement of capital as

8 9

shipping services. TNT asked the Polish tax authorities

for an interpretation of the national VAT provisions on

how to establish the time at which TNT was liable to

pay VAT on its services. The Polish tax authorities took

the view that a distinction had to be made between the

courier and postal services on the one hand and the

transport and shipping services on the other. Regarding

the transport and shipping services, the tax authorities

were of the opinion that receipt of the payment gave rise

to liability of payment of VAT, but that such liability arose

at the latest 30 days from the date on which the services

were supplied. TNT claimed that this was not in line with

Article 66 of the EU VAT Directive and went to court. In

the following proceedings the matter ended up before

the Supreme Administrative Court, which court decided

to refer preliminary questions to the CJ.

Based on Article 63 of the EU VAT Directive, VAT

becomes due, in principle, on the date on which goods

or services have been supplied. However, Article 66

of the EU VAT Directive authorizes Member States to

provide that VAT becomes due at certain other specific

times. In this regard, the CJ ruled that the Polish

implementation was not covered by Article 66 of the

EU VAT Directive. According to the CJ, EU VAT law

therefore precludes national legislation which provides

that, in respect of transport and shipping services, VAT

is to become chargeable on the date on which payment

is received in full or in part, but no later than 30 days

from the date on which those services are supplied,

even where the invoice has been issued earlier and

specifies a later deadline for payment.

CJ clarifies rules on repayment of input VAT for which the deduction was prevented in breach of EU VAT law (Alakor) On 16 May 2013, the CJ delivered its judgment in

the Alakor case (C-191/12). The case concerns

the Hungarian company Alakor Gabonatermelő és

Forgalmazó Kft (‘Alakor’), which concluded a subsidy

contract with the Ministry of Agriculture and Rural

Development. Based on a national provision, Alakor

was not entitled to deduct input VAT on the subsidised

assessed the taxable amount of VAT due in respect of

those vehicles based on the open market value of the

vehicles.

Mr. Marinov did not agree with the tax assessment

notice and brought an action before the Administrative

Court of Varna. Mr. Marinov claimed that the assets

should not have been assessed based on their open

market value and that depreciation should have been

taken into account. The Administrative Court of Varna

decided to refer preliminary questions to the CJ, asking

whether the Bulgarian national provisions were in line

with Article 74 of the EU VAT Directive and whether that

Article has direct effect.

The CJ first answered the question whether the

cessation of the taxable economic activity resulting from

the removal of the taxable person from the VAT register

is also covered by Article 18(c) of the EU VAT Directive.

According to the CJ, Article 18(c) of the EU VAT

Directive covers the cessation of a taxable economic

activity in general, without differentiating between the

causes or the circumstances of that cessation, and

excluding only the particular cases referred to in Article

19 of the EU VAT Directive.

Regarding the value of the assets to be taken into

account, the CJ ruled that the value is determined at the

time of the cessation, which therefore takes into account

the change in the value of those assets between their

acquisition and the cessation. According to the CJ,

depreciation should therefore be taken into account.

Finally, the CJ ruled that Article 74 of the EU VAT

Directive has direct effect.

CJ rules on Polish provision on how to establish the time a company becomes liable to pay VAT (TNT Express Worldwide) On 16 May 2013, the CJ delivered its judgment in case

C-169/12. The case concerns TNT Express Worldwide

(Poland) so. Z o.o. (‘TNT’), a company established in

Poland, that carries out courier, postal, transport and

9

Commission notice on test case for private VAT rulings The Commission has published an Information Notice

in which it has indicated that several Member States

have agreed to participate in a test case for private

VAT rulings relating to cross border situations. The

participating Member States are Belgium, Estonia,

Spain, France, Cyprus, Lithuania, Latvia, Malta,

Hungary, the Netherlands, Portugal, Slovenia and

the UK. Taxable persons planning complex cross-

border transactions to one or more of the participating

Member States may ask for such a ruling with regard to

transactions they envisage.

On the basis of the request, the Member States

concerned will consult each other. However, the process

does not guarantee that the Member States will agree

on the VAT treatment of the transactions envisaged. The

test case is foreseen to start on 1 June 2013 and to end

on 31 December 2013.

Commission communication on request for derogating measure for Germany On 16 May 2013, the Commission issued a

Communication in which objected to Germany

continuing to apply the reverse charge mechanism, in

derogation of Article 193 of the EU VAT Directive, in

relation to supplies of mobile phones and integrated

circuit devices. The Commission indicated that the

measure was never intended to be a long term solution

and was intended to allow Germany to put in place

other conventional anti-fraud measures in the sector.

According to the Commission, in this regard, an

automated evaluation mechanism, linked to specific VAT

declaration obligations, was put in place. Therefore, the

Commission sees no need to allow Germany to continue

the derogation. Moreover, the Commission indicated

that the continuation of the derogation would represent

a fraud risk for other Member States of the EU, as the

fraud has apparently shifted to these sectors in other

Member States.

project insofar as it was financed with the subsidy.

However, the non-deductible VAT due to the subsidy

could be claimed as ‘eligible expenditure’ under Ministry

of Finance guidelines.

In the PARAT Automotive Cabrio case (C-74/08) the

CJ held that national legislation which, in the case of

acquisition of goods subsidized by public funds, allows

the deduction of related VAT only up to the limit of the

non-subsidized part of the costs of that acquisition, is

precluded by EU VAT law. Therefore, Alakor considered

that it could deduct the entirety of the input VAT paid for

its taxable operations and that the input VAT previously

considered as non-deductible could not continue to form

part of the ‘eligible expenditure’ of the project. Alakor

applied for a refund of the VAT with interest for late

payment. The tax authorities granted the VAT refund,

but set the sum at a lower amount in view of the fact that

Alakor had already received part of the VAT as ‘eligible

expenditure’ from the Ministry of Agriculture and Rural

Development. Alakor claimed that the tax authorities

had incorrectly restricted the right to deduct and went

to court. In the subsequent proceedings, the Court of

Cassation decided to refer preliminary questions to the

CJ.

According to the CJ, a Member State, in principle, must

repay the entirety of the VAT which a taxable person

was prevented from deducting in breach of EU VAT

law. However, the CJ ruled that a Member State may

refuse to repay part of the VAT on the ground that such

repayment would give rise to unjust enrichment for the

benefit of the taxable person. In order to neutralize

the economic burden relating to the prohibition on

deducting VAT, the CJ ruled that the amount of the

repayment which Alakor may claim must correspond to

the difference between the amount of VAT which Alakor

was unable to deduct due to the national legislation

incompatible with EU VAT law, and the amount of aid

granted to Alakor that exceeded the aid which would

have been granted had Alakor not been prevented from

exercising its right to deduct.

10

actions taken by non-EU countries against EU exports.

In 2012 there were 138 cases against European

exports, eight less than the year before but still 15 more

than in 2010. The report shows that the Commission

successfully defends European firms. The WTO ruling

on Chinese X-ray scanners is one of the most significant

cases in this regard. Its systemic nature will ensure a

direct impact on other cases.

Launch of anti-subsidy investigation on solar glass from China On 27 April, the European Commission launched an

anti-subsidy investigation on imports of solar glass from

China. The association EU ProSun Glass lodged a

complaint claiming that solar glass from China is being

subsidised in China and then sold in the EU at prices

below market value. The complainant brought sufficient

elements justifying the need for an initiation. The

process could take up to 13 months but, under trade

defence rules, the EU could impose provisional anti-

subsidy duties within nine months if it considers these

necessary. Throughout the investigation, all interested

parties have a right to make their views and arguments

heard by sending in comments to the Commission

and/or taking part in hearings. The Commission takes

account of the comments received and addresses these

in the remainder of the investigation.

Commission meets experts on customs controls of trans-boundary waste shipmentsOn 15/16 May 2013, the Commission organized its

second expert group meeting on customs controls of

trans-boundary waste shipments in the framework of

the Customs Action to protect Health, Cultural Heritage,

the Environment and Nature. The meeting gathered

experts of the customs and environmental authorities

of EU Member States, China, Ghana, and India as well

as representatives from international organizations

including the Basel Convention Secretariat, the IMPEL,

and INTERPOL, and the recycling industry. The meeting

provided a sound information and cooperation platform

to understand the interests and approach of different

parties on the control procedures on trans-boundary

waste shipments.

Customs Duties, Excises and other Indirect TaxesThe European Commission ready for an ex officio trade defence action against Chinese mobile telecommunications equipment On 15 May, the European Commission took a decision

in principle to open an ex officio anti-dumping and

anti-subsidy investigation concerning imports of mobile

telecommunications networks and their essential

elements from China. The European Commission

can now launch the procedure on its own initiative

without an official complaint by the EU industry, based

on prima facie evidence of unfair international trade

practice. However, the activation of the decision is on

hold to allow for an amicable solution with the Chinese

authorities. Exports of telecommunication network

equipment from China amount to approximately EUR 1

billion per year.

Discussion on EPA implementation with the Eastern and Southern African partners On 14 and 15 May 2013, the second high-level meeting

under the Interim Economic Partnership Agreement

(EPA) for Eastern and Southern Africa (ESA) was

successfully held in Mauritius. The meeting of the

EPA Committee, chaired by DG Trade Director P.

Thompson and Ambassador Konjuul of Mauritius, took

place exactly one year after Madagascar, Mauritius,

the Seychelles and Zimbabwe started implementing

the agreement with the European Union. The partners

reviewed trade, development and customs aspects of

the agreement, and adopted a joint statement on all

issues involved.

Commission reports on its successes in defending EU exports The European Commission submitted to the European

Parliament its 10th annual report on trade defence

11

Correspondents● Peter Adriaansen (Loyens & Loeff Luxembourg)

● Séverine Baranger (Loyens & Loeff Paris)

● Gerard Blokland (Loyens & Loeff Amsterdam)

● Alexander Bosman (Loyens & Loeff Rotterdam)

● Kees Bouwmeester (Loyens & Loeff Amsterdam)

● Almut Breuer (Loyens & Loeff Amsterdam)

● Mark van den Honert (Loyens & Loeff Amsterdam)

● Leen Ketels (Loyens & Loeff Brussel)

● Sarah Van Leynseele (Loyens & Loeff Brussel)

● Raymond Luja (Loyens & Loeff Amsterdam;

Maastricht University)

● Arjan Oosterheert (Loyens & Loeff Amsterdam)

● Lodewijk Reijs (Loyens & Loeff Eindhoven)

● Bruno da Silva (Loyens & Loeff Amsterdam;

University of Amsterdam)

● Patrick Vettenburg (Loyens & Loeff Eindhoven)

● Ruben van der Wilt (Loyens & Loeff Amsterdam)

www.loyensloeff.com

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Editorial boardFor contact, mail: eutaxalert@loyensloeff.com:

● René van der Paardt (Loyens & Loeff Rotterdam)

● Thies Sanders (Loyens & Loeff Amsterdam)

● Dennis Weber (Loyens & Loeff Amsterdam;

University of Amsterdam)

Editors● Patricia van Zwet

● Bruno da Silva

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