In this contribution to the Special Issue of European Taxation on treaty override the author outlines the complexity of the issue in the context of the rising importance of anti-avoidance, highlights the difference between treaty override and interpretation conflicts, provides a case study on...

As of 2013, Belgium has been levying a new tax called the "fairness tax". The tax consists in a separate corporate tax assessment of 5.15% levied on profit distributions by Belgian companies or branches that do not realize taxable profits because of the offsetting of previous losses or the...

This article examines the decision in Austria v. Germany (Case C-648/15), which was submitted to the ECJ pursuant to the Austria–Germany Income and Capital Tax Treaty (2000). The author examines (1) the EU law aspects of the decision, in particular the Court’s jurisdiction to hear tax treaty...