The Resource The (in)compatibility of Polish CFC rules with the constitution pre and post-implementation of the EU Anti-Tax Avoidance Directive (2016/1164)

The (in)compatibility of Polish CFC rules with the constitution pre and post-implementation of the EU Anti-Tax Avoidance Directive (2016/1164)

Label
The (in)compatibility of Polish CFC rules with the constitution pre and post-implementation of the EU Anti-Tax Avoidance Directive (2016/1164)
Title
The (in)compatibility of Polish CFC rules with the constitution pre and post-implementation of the EU Anti-Tax Avoidance Directive (2016/1164)
Creator
Subject
Language
eng
Summary
This article identifies and examines selected aspects of the Polish CFC rules, both before and following their amendment in accordance with the EU Anti-Tax Avoidance Directive (2016/1164) (ATAD), with the aim of determining their constitutionality. The article concludes that various elements of the rules are unconstitutional, in particular following implementation of the ATAD
Citation source
In: European taxation. - Amsterdam. - Vol. 58 (2018), no. 4 ; p. 149-162
http://library.link/vocab/creatorName
Kuźniacki, B
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • ATAD
  • entity approach
  • PE
  • tax treaty
  • losses
  • constitutional law
  • proportionality
  • equal treatment
  • ability to pay
Label
The (in)compatibility of Polish CFC rules with the constitution pre and post-implementation of the EU Anti-Tax Avoidance Directive (2016/1164)
Instantiates
Publication
Label
The (in)compatibility of Polish CFC rules with the constitution pre and post-implementation of the EU Anti-Tax Avoidance Directive (2016/1164)
Publication

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