Evidence for eight node mixed-symmetry superconductivity in a correlated organic metal

We report a combined theoretical and experimental investigation of the superconducting state in the quasi-two-dimensional organic superconductor $\kappa$-(ET)$_2$Cu[N(CN)$_2$]Br. Applying spin-fluctuation theory to a low-energy material-specific Hamiltonian derived from ab initio density functional theory we calculate the quasiparticle density of states in the superconducting state. We find a distinct three-peak structure that results from a strongly anisotropic mixed-symmetry superconducting gap with eight nodes and twofold rotational symmetry. This theoretical prediction is supported by low-temperature scanning tunneling spectroscopy on in situ cleaved single crystals of $\kappa$-(ET)$_2$…

OS ECJ-TF 3/2015 on the Decision of the European Court of Justice in C.G. Sopora (Case C-512/13), on 'Horizontal Discrimination'

This article deals with the decision taken by the Court of Justice of the European Union in Sopora (Case C-512/13), which was decided by the Grand Chamber of the ECJ on 24 February 2015. It concerns the question of whether a specific requirement to obtain a tax advantage for foreign (incoming) workers violates the freedom of movement of workers (Art. 45 TFEU). This case prominently raises the issue of a differentiation not between nationals and non-nationals (i.e., "vertical discrimination"), but rather between different non-nationals (i.e., "horizontal discrimination") in the context of the taxation of payments of deemed employment expenses ("extraterritorial costs"). By clearly accepting …

LOCAL-MOMENT AND ITINERANT ANTIFERROMAGNETISM IN THE HEAVY-FERMION SYSTEM CE(CU1-XNIX)2GE2

Elastic and inelastic neutron-scattering studies on the system Ce(Cu1−xNix)2Ge2 are reported. These measurements are complemented by measurements of the magnetic susceptibility, high-field magnetization, heat capacity, thermal expansion, electrical resistivity and thermopower. The results reveal an interesting T-x phase diagram consisting of two different antiferromagnetic phases for x 0.5. Further experimental evidence for different types of antiferromagnetic ordering derives from a line-shape analysis of the quasielastic neutron-scattering intensity, from magnetization and thermopower experiments.

Opinion Statement ECJ-TF 1/2016 on the Judgment of 17 September 2015 of the Court of Justice of the EU in the Combined Cases C-10/14, Miljoen, C-14/14, X, and C-17/14, Société Générale, on the Dutch Dividend With-holding Tax

This article deals with the decision taken by the Court of Justice of the European Union in Miljoen and others (Joined Cases C-10/14, C-14/14 and C-17/14), in respect of which the Third Chamber of the Court of Justice of the European Union (ECJ) delivered its decision on 17 September 2015, following the Opinion of Advocate General Jaaskinen of 25 June 2015. The cases concern the taxation of dividends received by individual and corporate non-resident taxpayers. They answer several questions in respect of the appropriateness of levying dividend withholding taxes, such as the need to allow for an offset against ordinary income tax, the deductibility of related costs and the relevance of an off…

Proceedings Of The 23Rd Paediatric Rheumatology European Society Congress: Part Two

Disorder-induced gap in the normal density of states of the organic superconductorκ-(BEDT-TTF)2Cu[N(CN)2]Br

The local density of states (DOS) of the organic superconductor κ-(BEDT-TTF)2Cu[N(CN)2]Br, measured by scanning tunneling spectroscopy on in situ cleaved surfaces, reveals a logarithmic suppression near the Fermi edge persisting above the critical temperature T(c). The experimentally observed suppression of the DOS is in excellent agreement with a soft Hubbard gap as predicted by the Anderson-Hubbard model for systems with disorder. The electronic disorder also explains the diminished coherence peaks of the quasi-particle DOS below T(c).

OS ECJ-TF 1/2018 on the Compatibility of Limitation-on-Benefits Clauses with the EU Fundamental Freedoms

This article deals with compatibility of limitation-on-benefits (LoB) clauses with the EU fundamental freedoms, based on decisions of the European Court of Justice (ECJ). The context of this statement is the Commission's infringement procedure against the Netherlands with regard to the LoB clause in the Japan-Netherlands Income Tax Treaty (2010) and the inclusion of a simplified optional LoB clause in the BEPS Multilateral Instrument.

OS ECJ-TF 2/2019 on the ECJ Decisions of 26 February 2019 in N Luxembourg I et al. (Joined Cases C-115/16, C-118/16, C-119/16 and C-299/16) and T Danmark et al. (Joined Cases C-116/16 and C-117/17), Concerning the 'Beneficial Ownership' Requirement and the Anti-Abuse Principle in the Company Tax Directives

This article deals with the decision taken by the Court of Justice of the European Union in of 26 February 2019 in N Luxembourg I et al. (Joined Cases C-115/16, C-118/16, C-119/16 and C-299/16) and T Danmark et al. (Joined Cases C-116/16 and C-117/17). The authors acknowledge that the "Danish beneficial ownership cases" address a number of important and timely issues, especially with regard to the concept of abuse under EU law. These include: (i) the expansion of the general anti-abuse principle enshrined in EU law to areas of tax law that are subject to minimal harmonization; (ii) the use of OECD materials to define the beneficial ownership concept; (iii) the conflation of the beneficial o…

PAA-PAMPS Copolymers as an Efficient Tool to Control CaCO3 Scale Formation

Scale formation, the deposition of certain minerals such as CaCO3, MgCO3, and CaSO4 center dot 2H(2)O in industrial facilities and household devices, leads to reduced efficiency or severe damage. Therefore, incrustation is a major problem in everyday life. In recent years, double hydrophilic block copolymers (DHBCs) have been the focus of interest in academia with regard to their antiscaling potential. In this work, we synthesized well-defined blocklike PAA-PAMPS copolymers consisting of acrylic acid (AA) and 2-acrylamido-2-methyl-propane sulfonate (AMPS) units in a one-step reaction by RAFT polymerization. The derived copolymers had dispersities of 1.3 and below. The copolymers have then b…

Planar Benzo[1,2-b:4,5-b′]dithiophene Derivatives Decorated with Nitronyl and Imino Nitroxides

Four weakly antiferromagnetic interacting biradicals of benzo[1,2- b:4,5- b']dithiophene (BDT) and BDT extended with two thiophenes (BDTTh2) linked with nitronyl and imino nitroxides (NN and IN) as BDT-NN, BDT-IN, BDTTh2-NN, and BDTTh2-IN were designed, synthesized, and characterized. Short intermolecular π-π distances were found (3.42 A) for BDT-NN, whereas larger ones were found for BDT-IN (3.54 A) and BDTTh2-NN (3.67 A), respectively. Intramolecular magnetic interaction ( Jintra,exp/ kB) of BDT-NN (-26 K) is much larger than for BDT-IN (-5.3 K), while it is reduced for the dithiophene-extended molecule BDTTh2-NN (-2.3 K). Intermolecular interactions ( zJinter,exp/ kB) of BDT-NN (-6.5 K) …

OS ECJ-TF 2/2016 on the Decision of the Court of Justice of the European Union of 13 July 2016 in Brisal and KBC Finance Ireland (Case C-18/15), on the Admissibility of Gross Withholding Tax of Interest

This article examines the decision of the CJEU in Brisal and KBC Finance Ireland (Case C-18/15) of 13 July 2016. Following a Portuguese reference for a preliminary ruling, the Court's decision provides further clarification on the permissibility of withholding taxation within the European Union. In relation to interest, the Court held that non-resident taxpayers may be subject to withholding taxes (even if comparable residents pursuing the same activity are not) but that non-residents may nevertheless not be taxed on gross income (when comparable residents are taxed on net profits) and are, therefore, entitled to deduct expenses directly connected to their business activity.

Alloying experiments on heavy fermion compounds

Abstract This paper is intended to demonstrate the usefulness of controlled alloying for the understanding of heavy-fermion physics: (1) Th-substitution for Ce in CeCu2Si2 emphasizes the dominating role of the dopant-induced strain fields in generating incoherent scattering and pair breaking, (2) replacement of Cu by Ni in Ce(Cu1-xNix)2Ge2 leads to phenomena which are interpreted as derived from a transition between local-moment and itinerant heavy-fermion magnetism, and (3) increasing Cu concentration in UCu4+xAl8-x is accompanied by an antiferromagnetic to nonmagnetic transition near xcr = 1.5 similar to what has been found before for several Ce-based systems. A heavy Fermi-liquid phase w…

Opinion Statement ECJ-TF 4/2019 on the CJEU Decision of February 26, 2019, in Case C-135/17, X-GmbH, Concerning the Application of the German CFC Legislation in Relation to Third Countries

This article deals with case, X-GmbH (Case C-135/17) concerning the compatibility of German CFC legislation with regard to third countries. In Germany, CFC legislation only applies in cross-border situations and not in purely domestic situations. In general, the application of CFC legislation requires that the shareholders have control over the foreign subsidiary, that the foreign subsidiary be taxed at a lower rate and that it earn passive income. Concerning a special type of passive income, there is even no control requirement. In relation to other EU and EEA countries, Germany does not apply its CFC legislation if the taxpayer proves that the company carries on a genuine economic activit…

Instabilities in heavy-fermion systems

Abstract We review (i) an itinerant antiferromagnetic phase transition below 4 K in Ni-rich Ce(Cu 1− x Ni x ) 2 Ge 2 systems, (ii) the coincidence at T = 0.63 K of both a structural lattice instability in “as-grown” (non-superconducting) CeCu 2 Si 2 single crystals and bulk superconductivity in annealed ones as well as (iii) antiferromagnetic and superconducting transitions at T N = 4.6 K and T c = 1 K, respectively, in the heavy-fermion compound UNi 2 Al 3 .

OS ECJ-TF 1/2019 on the ECJ Decision of 31 May 2018 in Hornbach-Baumarkt (Case C-382/16) Concerning the Application of Transfer Pricing Rules to Transactions between Resident and Non-Resident Associated Enterprises

This article is focused on the Court's decision in Hornbach-Baumarkt (Case C-382/16) (Hornbach) which is an important clarification of the conditional compatibility of arm's length-based domestic transfer pricing legislation with the freedom of establishment. Hornbach follows and confirms the previous doctrine formulated in SGI (Case C-311/08). The decision did not follow Advocate General's approach, which would have denied comparability of domestic and cross-border situations in transfer pricing cases and, hence, prevent scrutiny of domestic transfer pricing legislation under the fundamental freedoms. The authors welcome the requirement that Member States have to grant taxpayers the opport…

Magnetic phase diagrams in heavy-fermion compounds

Magnetic phase diagrams have been explored in heavy-fermion (HF) compounds by controlled changes of the stoichiometry (UCu4+xAl8−x), dopant concentration (Ce(Cu1−xNix)2Ge2) and magnetic field (CeCu2Si2). The results demonstr competition (i) between Kondo and RKKY interactions in the former two compounds and (ii) between HF superconductivity and some cooperative state, presumably HF band magnetism, in the latter.

OS 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 Multi-State Situations

This article deals with the decision taken by the Court of Justice of the European Union in X (Case C-283/15), on 9 February 2017. In general terms, the Court followed the Opinion of Advocate General Wathelet of 7 September 2016. The case concerned tax legislation permitting the deduction of "negative income" relating to a dwelling. The issue was whether the fundamental freedoms must be interpreted as precluding a Member State from refusing the benefit of that deduction in respect of a self-employed non-resident in circumstances in which that person receives 60% of his total income within that Member State, and 40% within a non-Member State. Therefore, he does not receive income that enable…

Alloying-induced transition from local-moment to itinerant heavy fermion magnetism in Ce(Cu1−xNix)2Ge2

Abstract A monotonous increase of the Kondo temperature in Ce(Cu1−xNix)2Ge2 from 7 (x = 0) to 30 K (x = 1) is accompanied by drastic changes of ground state properties: for x⩽0.2, a modulated magnetic structure (q01 = (0.28, 0.28, 0.54)) involving Kondo-reduced local Ce moments ( μ s = 0.74μ B Ce for x = 0) forms below TN1(x). TN1 = 4. 1 K for CeCu2Ge2 is strongly depressed upon increasing x. At x ≲ 0.2, a different modulation develops below TN2(x) which becomes maximum (≃4 K) for x = 0.5. Since this is characterized by a very small value of q02 (=(0, 0, 0.13) at x = 0.5) and a gradually decreasing ordered moment (reaching μs ≲ 0.2μB/Ce for x ⩾0.65), we ascribe it to “heavy fermion band mag…

Opinion Statement ECJ-TF 3/2019 on the CJEU Decision of 22 November 2018 in Case C-575/17, Sofina, on Withholding Taxes, Losses and Territoriality

This article deals with the decision taken by the Court of Justice of the European Union in Sofina. In the authors' view, it may have extended the standard of comparability, requiring (foreign) non-dividend income of the recipient to be taken into consideration in comparing the tax treatment of domestic and outbound dividends. This comparator, however, upsets the principle of territoriality, as accepted by the Court in Futura (Case C-250/95) and Centro Equestre (Case C-345/04), by requiring the source state to take into account losses that the non-resident taxpayer has in the residence state. Taken at face value, Sofina's impact may extend well beyond withholding taxes, specifically, and di…

Investigation of Many‐Body Effects in the Quasi‐Two‐Dimensional Electronic System of Organic Charge‐Transfer Salts

Photoconductivity of Poly(Arylenevinylene)S and Poly(Hetarylenevinylene)S

Abstract The intramolecular condensation of aromatic Schiff bases leads under strong alkaline conditions to the poly(arylenevinylene)s and poly(hetarylenevi-nylene)s A - H. Due to the extreme stereoselectivity the resulting products are rigid, (E)-configurated polymers. The broad band gap of the unsubstituted intrinsic insulators is decreased by alkoxy substituents. Investigations of the photoconductivity and the photoreactivity, as well as of the AC-conductivity of some undoped, doped and quaternized systems are performed.

OS ECJ-TF 1/2020 on the General Court Decisions of 24 September 2019 in The Netherlands v. Commission (Starbucks) (Joined Cases C-760/15 and T-636/16) and Luxembourg v. Commission (Fiat Finance and Trade) (Joined Cases T-755/15 and T-759/15), on State Aid Granted by Transfer Pricing Rulings

This article provides a comprehensive exame of the decisions of the EU General Court in the cases The Netherlands v. Commission (Starbucks) (Joined Cases C-760/15 and T-636/16) (hereinafter Starbucks NL) and Luxembourg v. Commission (Fiat Finance and Trade) (Joined Cases T-755/15 and T-759/15) (hereinafter Fiat), decided on 24 September 2019. These are the first in a series of expected decisions concerning the legality of the European Commission's decisions considering certain transfer pricing rulings granted by Member States to multinational enterprises (hereinafter MNEs) to constitute State aid. The GC reached different verdicts in the two cases. Whereas in Starbucks NL it annulled the Co…

Magnetic order in the heavy fermion system Ce(Cu1−xNix)2Ge2

Abstract The magnetic phase diagram of the heavy fermion (HF) systems Ce(Cu 1−x Ni x ) 2 Ge 2 is discussed utilizing results of transport, thermodynamic and neutron-scattering measurements. While the Kondo temperature increases monotonically with x, a complex x-dependence is found for the Neel temperature, associated with a transition from local-moment to itinerant HF magnetism.

OS 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

This article deals with the decision taken by the Grand Chamber of the Court of Justice of the European Union in World Duty Free Group (formerly Autogrill Espana); Banco Santander and Santusa Holding (Joined Cases C-20/15 P and C-21/15 P), on 21 December 2016, following decisions of the General Court of the European Union of 7 November 2014 in Autogrill Espana and of 7 November 2014 in Banco Santander and Santusa and the Opinion of Advocate General Wathelet of 28 July 2016. The case concerned Spanish tax rules that allowed Spanish enterprises tax amortization of financial goodwill arising from the acquisition of shareholdings in foreign companies, but not from the acquisition of shareholdin…

Opinion statement ECJ-TF 4/2014 of the CFE on the decision of the European Court of Justice of 23 January 2014 in SCA Group Holding BV et al. (joined cases C-39/13, C-40/13 and C-41/13), on the requirements to form a 'fiscal unity'

This Opinion Statement analyses the Court's decision in Joined Cases C‑39/13, C‑40/13 and C‑41/13, SCA Group Holding BV et al, of 12 June 2014, concerning the question whether the Netherlands violate the provisions on freedom of establishment if they refuse to form a "fiscal unity" ("fiscale eenheid") between domestic companies in cases where one or more intermediate companies are residents of another Member State (C-39/13 and C-41/13) or (2) the common parent company of two domestic sister companies is resident in another Member State (C-40/13). The Dutch "fiscal unity" treats separate entities as one taxable unit for corporate income tax purposes and hence enables, e.g., the full consolid…

Opinion statement ECJ-TF 4/2015 of the CFE on the decision of the European Court of Justice in Groupe Steria SCA (Case C-386/14) on the French Integration Fiscale

This is an Opinion Statement prepared by the CFE ECJ Task Force1 on Case C-386/14, in which the 2nd Chamber of the Court of Justice of the European Union (ECJ) delivered its judgment on 2 September 2015, following the opinion of Advocate General Kokott of 11 June 2015.3 The judgment, which has also been the object of an ECJ press release, is a further interpretation of the freedom of establishment in the context of the French "intégration fiscale" and clarifies that taxpayers can claim some benefits of group taxation regime even if EU law would not allow them the full benefit of such regime. It also confirms that an option granted to Member States in secondary EU legislation cannot justify …

Opinion statement ECJ-TF 2/2015 of the CFE on the decision of the European Court of Justice in Commission v. United Kingdomm ('final lossess') (case C-172/13), concerning the 'Marks & Spencer exception'

This is an Opinion Statement prepared by the CFE ECJ Task Force on Case C-172/13, European Commission v United Kingdom, which was decided by the Grand Chamber of the Court of Justice of the European Union (ECJ) on February 2015. This case is in some ways a follow-up to the ECJ's decision in Marks & Spencer and comments on whether the legislative amendments introduced by the United Kingdom are sufficient to ensure compliance with European Union law. After illustrating the case, arguments of the parties and decision of the Court, this Opinion Statement will focus on selected critical points from the Courts decision and Advocate General Kokott's opinion.

OS 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

This article examines the decision of the Grand Chamber of the Court of Justice of the European Union (ECJ) in Berlioz Investment Fund SA (Case C-682/15) delivered on 16 May 2017, following the Opinion of Advocate General Wathelet of 10 January 2017. The case concerned the levying of tax penalties in circumstances in which a third party partially refused to provide the Luxembourg tax authorities with information requested, by way of mutual assistance under the Mutual Assistance Directive (2011/16), by the French tax authorities. Having clarified that when exchanging information by way of mutual assistance under an EU directive, EU Member States are implementing EU Law, the Grand Chamber con…

Opinion statement ECJ-TF 4/2013 of the CFE on the decision of the European Court of Justice in Etwein (Case C-425/11)

This Opinion Statement analyses the ECJ decision on the Case C-425/11 Katja Ettwein, concerning a personal tax advantage for self-employed frontier workers under the 2002 ECSwitzerland Agreement on the free movement of persons (the "Agreement")

Opinion statement ECJ-TF 3/2015 of the CFE on the decision of the European Court of Justice in C.G. Sopora (Case C-512/12) on 'horizontal discrimination'

On 24 February 2015, the Grand Chamber of the ECJ handed down its decision in Case C-512/13, C.G. Sopora, concerning the question of whether a specific requirement to obtain a tax advantage for foreign (incoming) workers violates the freedom of movement of workers (Art. 45 TFEU). This case prominently raises the issue of a differentiation not between nationals and non-nationals (i.e., "vertical discrimination"), but rather between different non-nationals (i.e., "horizontal discrimination") in the context of the taxation of payments of deemed employment expenses ("extraterritorial costs"). By clearly accepting such "horizontal comparison" in the context of Art. 45 TFEU, it resolves a questio…

Opinion statement ECJ-TF 3/2014 of the CFE on the decision of the European Court of Justice of 23 January 2014 in DMC (Case-164/12), concerning taxation of unrealized gains upon a reorganization within the UE

This is an Opinion Statement prepared by the CFE ECJ Task Force1 on Case C-164/12, DMC. After illustrating the facts of the DMC case and the preliminary questions, this document will focus on selected critical points from this case by pointing out some differences between it and its most immediate relevant precedent, National Grid Indus, which has been the subject of a previous Opinion Statement by the CFE.4

Opinion statement ECJ-TF 1/2015 of the CFE on the decision of the European Court of Justice in Commission v. Spain (Case C-127/12) and Commission v. Germany (Case C-211/13) concerning inheritance taxation

The cases Commission v. Spain (C-127/12) and Commission v. Germany (C-211/13) have common features and in both cases the ECJ (second and third chamber) held that the two national measures at issue were contrary to the free movement of capital ensured under Art 63 TFEU and under Art 40 of the EEA Agreement. Both cases were decided without an opinion from the designated Advocates General, Kokott and Mengozzi, respectively.

CCDC 1862382: Experimental Crystal Structure Determination

Related Article: Kubandiran Kolanji, Lars Postulka, Bernd Wolf, Michael Lang, Dieter Schollmeyer, and Martin Baumgarten|2019|J.Org.Chem.|84|140|doi:10.1021/acs.joc.8b02499

CCDC 1862545: Experimental Crystal Structure Determination

Related Article: Kubandiran Kolanji, Lars Postulka, Bernd Wolf, Michael Lang, Dieter Schollmeyer, and Martin Baumgarten|2019|J.Org.Chem.|84|140|doi:10.1021/acs.joc.8b02499

CCDC 1862543: Experimental Crystal Structure Determination

Related Article: Kubandiran Kolanji, Lars Postulka, Bernd Wolf, Michael Lang, Dieter Schollmeyer, and Martin Baumgarten|2019|J.Org.Chem.|84|140|doi:10.1021/acs.joc.8b02499

CCDC 1862542: Experimental Crystal Structure Determination

Related Article: Kubandiran Kolanji, Lars Postulka, Bernd Wolf, Michael Lang, Dieter Schollmeyer, and Martin Baumgarten|2019|J.Org.Chem.|84|140|doi:10.1021/acs.joc.8b02499

CCDC 1862544: Experimental Crystal Structure Determination

Related Article: Kubandiran Kolanji, Lars Postulka, Bernd Wolf, Michael Lang, Dieter Schollmeyer, and Martin Baumgarten|2019|J.Org.Chem.|84|140|doi:10.1021/acs.joc.8b02499