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This article examines the compatibility of the OECD's proposed rules on GloBE (pillar II) with EU law, covering both primary law and secondary law. In addition, it discusses the amendments required by the implementation of this initiative within the internal market. In what concerns...
Persistent link: https://www.econbiz.de/10012826846
Portuguese abstract: Este livro fornece uma visão abrangente da forma como o Tribunal de Justiça da União Europeia aplica a análise da proporcionalidade, especialmente no que diz respeito à avaliação da compatibilidade das regras de tributação direta nacionais com as liberdades...
Persistent link: https://www.econbiz.de/10012828859
administrative perspective, offering its readers a balanced view of rights and obligations connected with the levying of taxes. The … levying of taxes in a global setting. Furthermore, the book provides basic notions of taxation required for building a …
Persistent link: https://www.econbiz.de/10012828861
and gift taxes in light of the free movement of capital and expects the member states to adjust their domestic laws … accordingly. The authors also welcome the initiatives of the Commission in the inheritance and gift taxes field and, since only …
Persistent link: https://www.econbiz.de/10012829030
This article deals with the decision taken by the Court of Justice of the European Union in Groupe Steria SCA (Case C-386/14), in respect of which the Second Chamber of the Court of Justice of the European Union (ECJ) delivered its decision on 2 September 2015, following the Opinion of Advocate...
Persistent link: https://www.econbiz.de/10012829032
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)...
Persistent link: https://www.econbiz.de/10012829033
Persistent link: https://www.econbiz.de/10012829034
questions in respect of the appropriateness of levying dividend withholding taxes, such as the need to allow for an offset …
Persistent link: https://www.econbiz.de/10012829035
In this article, the author makes a critical exam of a decision of the Portuguese Supreme Administrative Court which interprets the prohibition of discriminatory treatment as enshrined in tax treaties and assesses whether nationals of another State may access, in the same conditions, tax...
Persistent link: https://www.econbiz.de/10012829039
Persistent link: https://www.econbiz.de/10012829041