The Resource Holding companies and leveraged buy-outs in the European Union following BEPS: beneficial ownership, abuse of law and the single taxation principle (Danish ECJ Cases C-115/16, 116/16, 117/16, 118/16, 119/16 and 299/16)
Holding companies and leveraged buy-outs in the European Union following BEPS: beneficial ownership, abuse of law and the single taxation principle (Danish ECJ Cases C-115/16, 116/16, 117/16, 118/16, 119/16 and 299/16)
Resource Information
The item Holding companies and leveraged buy-outs in the European Union following BEPS: beneficial ownership, abuse of law and the single taxation principle (Danish ECJ Cases C-115/16, 116/16, 117/16, 118/16, 119/16 and 299/16) represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Holding companies and leveraged buy-outs in the European Union following BEPS: beneficial ownership, abuse of law and the single taxation principle (Danish ECJ Cases C-115/16, 116/16, 117/16, 118/16, 119/16 and 299/16) represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- In this article, the author discusses the highly anticipated European Court of Justice Danish beneficial ownership cases, which address treaty and directive shopping scenarios within the area of corporate finance and corporate reorganization. The broad interpretation of beneficial ownership and abuse of EU Law in the EU Interest and Royalties (2003/49) and Parent-Subsidiary (2011/96) Directives given by the Court may lead to significant uncertainty, as well as inconsistencies that will need further clarification
- Language
- eng
- Label
- Holding companies and leveraged buy-outs in the European Union following BEPS: beneficial ownership, abuse of law and the single taxation principle (Danish ECJ Cases C-115/16, 116/16, 117/16, 118/16, 119/16 and 299/16)
- Title
- Holding companies and leveraged buy-outs in the European Union following BEPS: beneficial ownership, abuse of law and the single taxation principle (Danish ECJ Cases C-115/16, 116/16, 117/16, 118/16, 119/16 and 299/16)
- Language
- eng
- Summary
- In this article, the author discusses the highly anticipated European Court of Justice Danish beneficial ownership cases, which address treaty and directive shopping scenarios within the area of corporate finance and corporate reorganization. The broad interpretation of beneficial ownership and abuse of EU Law in the EU Interest and Royalties (2003/49) and Parent-Subsidiary (2011/96) Directives given by the Court may lead to significant uncertainty, as well as inconsistencies that will need further clarification
- Citation source
- In: European taxation. - Amsterdam. - Vol. 59 (2019), no. 9 ; p. 409-421
- http://library.link/vocab/creatorName
- Hernández González-Barreda, P.A
- Geographic coverage
-
- European Union
- Europe
- Language note
- English
- http://library.link/vocab/subjectName
-
- ECJ case law
- treaty shopping
- holding company
- leveraged buy-out
- beneficial ownership
- BEPS
- abuse of law
- fundamental freedoms
- discrimination
- single tax principle
- Interest and Royalties Directive
- Parent-Subsidiary Directive
- royalties
- private equity
- GAAR
- Label
- Holding companies and leveraged buy-outs in the European Union following BEPS: beneficial ownership, abuse of law and the single taxation principle (Danish ECJ Cases C-115/16, 116/16, 117/16, 118/16, 119/16 and 299/16)
- Label
- Holding companies and leveraged buy-outs in the European Union following BEPS: beneficial ownership, abuse of law and the single taxation principle (Danish ECJ Cases C-115/16, 116/16, 117/16, 118/16, 119/16 and 299/16)
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Holding-companies-and-leveraged-buy-outs-in-the/jBGPQsJ3azs/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Holding-companies-and-leveraged-buy-outs-in-the/jBGPQsJ3azs/">Holding companies and leveraged buy-outs in the European Union following BEPS: beneficial ownership, abuse of law and the single taxation principle (Danish ECJ Cases C-115/16, 116/16, 117/16, 118/16, 119/16 and 299/16)</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
