The Resource Evaluation of the earnings stripping rules

Evaluation of the earnings stripping rules

Label
Evaluation of the earnings stripping rules
Title
Evaluation of the earnings stripping rules
Creator
Subject
Language
eng
Summary
Member States had to have implemented the anti-earnings stripping rules by 1 January 2019. In this article these rules are evaluated from an economic and EU law perspective. The author concludes that the rules are probably not in breach of EU law because they are implemented without distinction between domestic and cross border situations. In addition there is little room to assess rules which are the result of (full) harmonization. Nevertheless some risks exist in particular with regard to the interaction between the group regimes and the earning stripping rules and the design of the standalone exception. An important drawback of the earnings stripping rules is the risk of double taxation. This could have been avoided by the EU legislator
Citation source
In: EC tax review. - Alphen aan den Rijn. - Vol. 29 (2020), no. 4 ; p. 158-177
http://library.link/vocab/creatorName
Stevens, S.A
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • earnings stripping
  • thin capitalization
  • ATAD
  • EU law
  • BEPS Project (OECD)
  • EBITDA
  • interest deduction
  • double taxation
Label
Evaluation of the earnings stripping rules
Instantiates
Publication
Label
Evaluation of the earnings stripping rules
Publication

Library Locations

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