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)

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)
Creator
Subject
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)
Instantiates
Publication
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)
Publication

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