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Persistent link: https://www.econbiz.de/10013348075
The century old international tax system is in the middle of being rebuilt. Between the hope of countries being able to reach a fair and balanced compromise, and the fear of the looming tax war finally breaking out, this article inquires whether the EU should implement a minimum taxation regime...
Persistent link: https://www.econbiz.de/10012822595
The purpose of this article is to explore to what extent EU State aid rules may promote equity in international corporate taxation, whereby we focus on the notion of inter taxpayer equity. Upon the outlining of the analytical framework necessary to conduct such inquiry, we briefly describe the...
Persistent link: https://www.econbiz.de/10012825102
Recent ECJ case law regarding the taxation of investment funds seems to include elements of mutual recognition which is a rare phenomenon in the Court´s doctrine on direct taxation. Expanding on the rather clear positions of the Court in E, Veronsaajien oikeudenvalvontayksikkö (C-480/19) and A...
Persistent link: https://www.econbiz.de/10014353296
Art. 6 of the Anti Tax Avoidance Directive (ATAD) includes a minimum harmonization standard for so-called General Anti Abuse Rules (GAARs) in the field of corporate income taxation. A significant number of Member States has not enacted the provision but referred to their domestic law already...
Persistent link: https://www.econbiz.de/10014243763