This article examines the compatibility of the Anti-Tax Avoidance Directive (ATAD) with primary EU law on four grounds. First, it argues that the Directive is incompatible with the general principle of anti-abuse developed by the CJEU. Second, it considers the Directive to not comply with the...

The paper analyzes the opinion of AG Hogan in the case GVC Services (C-458/18). The author argues that the Parent-Subsidiary Directive should be applicable to a parent company, incorporated in Gibraltar even if, as the case may be, this applicability derives from a teleological interpretation of...

This article outlines weaknesses in the EU deposit insurance legal framework and proposes necessary amendments in its substantive rules to enhance the system's ability to ensure financial stability by preventing bank runs. It first examines the overall relationship between systemic liquidity...

This paper analyses the potential impact of the minimum tax envisaged under the OECD Pillar Two on several common corporate tax incentives. It reaches the conclusion that while the impact is expected to be low to moderate for some common incentives, such as participation exemption regimes and...

This article aims at identifying the most relevant shortcomings of any initiative of fighting against abuse of the right of establishment on the basis of a priori set substance indicators. It does so by reference to the Unshell Directive proposal against the broader background of the need to...

The present study was developed based on the IBFD EU Task Force’s submission within the framework of the European Commission 2021 public consultation on the use of shell entities and arrangements for tax purposes. The analysis of the broad ramifications of this central issue within corporate...