This book provides a concise, practical guide to the European Union's Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD's five specific anti-avoidance rules, its chapters explain the background of those rules, the directive's interactions with relevant jurisprudence, and the challenges posed to the ATAD's interpretation and implementation in domestic law. Key features include:* critical, article-by-article analysis of the ATAD* contextual information on the legislative environment in which the ATAD operates, embedding it in the wider landscape of CJEU jurisprudence* insights into the day-to-day application of the ATAD rules in practice* contributions from leading academics and practitioners in the field of tax law* examples of the challenges to its interpretation and implementation, taken from a range of EU Member States.European and international tax advisors, along with policy makers in the field of tax law, will find this book to be a comprehensive yet accessible guide to the ATAD and its correct application. Those who carry out research in European tax law can also benefit from this book's critical approach to the ATAD and the questions that surround anti-tax avoidance legislation in the European Union.
This fifth edition has enhanced the analysis of the implications of the EU Charter of Fundamental Rights for direct taxes and significantly revises the structure and content of the chapters on fundamental freedoms and State aid.
Essays in International and European Tax Law, Jovene Editore, Napoli (2010). Gozdziowska P., Kuzniacki B. and Wickel T., Poland in: Cahiers de droit fiscal international Vol. 99B, Qualification of Taxable Entities and Tax Treaty ...
... already considered the implications of corporate financing from different perspectives and its connection with respect to different fields of economy and law, such as corporate finance theory, company law, financial accounting law, ...
Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in ...
As a highly informative and closely reasoned guide that offers clear perspectives on resolving any conflict that may arise between a directive and a tax treaty, this book will be of inestimable value for tax practitioners and advisers, ...
402-408 (2010), Journals IBFD about the tax treatment of dividends paid to non-residents. See Pato, A. C. 2008, Cross-Border Direct Tax Issues of Investment Funds from the Perspective of European Law, EC Tax Review 5, pp.
The Final Reports on the 15 OECD Action Items against BEPS were released to the public on 5 October 2015.00On 29 May 2017, the Council of the European Union adopted Anti-Tax Avoidance Directive 2 (?ATAD 2?) that required EU Member States to ...
(22) Rolf Eicke, Tax Planning with Holding Companies. Repatriation of US Profits from Europe:Concepts, Strategies, Structures, 2008 (ISBN978-90-411-2794-5). (23) Peter Essers et al. (ed.), The Influence of IAS/IFRS on the CCCTB, ...
299 Notorious examples , in this respect , are Marks & Spencer , 214 Oy AA215 and X Holding.216 The Court started with three cumulative justifications in Marks & Spencer , reduced them to two in Oy AA and , eventually , had to admit ...
This book should also help academics without a legal background to approach the technical issues raised by European Union tax law. This edition contains selected relevant information available as of 30 June 2022.