In this article, the author examines group taxation within the European Union. In particular, the author analyses whether or not the European Court of Justice decision in Papillon and/or Art. 24(5) of the OECD Model Tax Convention oblige Member States to extend the personal scope of their group...

The European Union (EU) Merger Directive removes certain tax disadvantages encountered by companies and their shareholders in the course of a restructuring operation. However, in spite of amendments and European Court of Justice's (ECJ) interpretations of its provisions, various shortcomings...