The Resource Tax treaties between Member States and Third States : 'reciprocity' in bilateral tax treaties and non-discrimination in EC law

Tax treaties between Member States and Third States : 'reciprocity' in bilateral tax treaties and non-discrimination in EC law

Label
Tax treaties between Member States and Third States : 'reciprocity' in bilateral tax treaties and non-discrimination in EC law
Title
Tax treaties between Member States and Third States : 'reciprocity' in bilateral tax treaties and non-discrimination in EC law
Creator
Subject
Language
eng
Summary
This article discusses the subject of tax treaties between EU Member States and third states and their compatibility to EU law, including: a multilateral framework treaty between the EU and third states, non-discrimination of non-residents, rules on allocation of taxation powers and rules conferring tax advantages, the application of a most-favoured-nation clause where a third state is involved, the role of the most-favoured-nation clause in international trade versus the aim of tax treaties and intra-EU states neutral taxation, the compatibility with EU law of anti-abuse clauses in tax treaties between EU states and third states, and the compatibility with EU law of some limitation of benefits clauses and controlled foreign company clauses
Citation source
In: EC tax review. - London. - Vol. 15 (2006), no. 2 ; p. 83-94
http://library.link/vocab/creatorName
  • Vogel, K
  • Gutmann, D
  • Dourado, A.P
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • EU law
  • ECJ case law
  • tax treaty
  • anti-avoidance
  • non-discrimination
  • fiscal neutrality
  • MFN
  • CFC
  • LoB
Label
Tax treaties between Member States and Third States : 'reciprocity' in bilateral tax treaties and non-discrimination in EC law
Instantiates
Publication
Label
Tax treaties between Member States and Third States : 'reciprocity' in bilateral tax treaties and non-discrimination in EC law
Publication

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