The Resource Allocation of the burden of proof under the anti-abuse rule of the Parent-Subsidiary Directive according to the most recent ECJ case law

Allocation of the burden of proof under the anti-abuse rule of the Parent-Subsidiary Directive according to the most recent ECJ case law

Label
Allocation of the burden of proof under the anti-abuse rule of the Parent-Subsidiary Directive according to the most recent ECJ case law
Title
Allocation of the burden of proof under the anti-abuse rule of the Parent-Subsidiary Directive according to the most recent ECJ case law
Creator
Subject
Language
eng
Summary
The author examines the judgment rendered by the ECJ in the Deister Holding and Juhler Holding cases and its implications, with special regard to the allocation of the burden of proof between the tax authorities and the taxpayer. The author aims to investigate whether and to what extent Member States - in light of the most recent ECJ case law - are entitled to enact domestic anti-abuse rules which presume that abuse occurred under the Parent-Subsidiary Directive, as well as under the other directives on the harmonization of company taxation
Citation source
In: EC tax review. - Alphen aan den Rijn. - Vol. 27 (2018), no. 5 ; p. 267-279
http://library.link/vocab/creatorName
Sanò, C
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • ECJ case law
  • Parent-Subsidiary Directive
  • anti-avoidance
  • burden of proof
  • Merger Directive
  • Interest and Royalties Directive
Label
Allocation of the burden of proof under the anti-abuse rule of the Parent-Subsidiary Directive according to the most recent ECJ case law
Instantiates
Publication
Label
Allocation of the burden of proof under the anti-abuse rule of the Parent-Subsidiary Directive according to the most recent ECJ case law
Publication

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