This contribution lays down a general plan for what the EU should do in order to attain a harmonized set of norms regulating the allocation of taxing rights among Member States and in the relation between those States and third countries, which would benefit both Member States and their taxpayers by eliminating several instances of…

Introduction and EU law applicable On 8 March 2017 the Court of Justice of the European Union (hereafter “CJ”) delivered its decision in the Case C-448/15, Wereldhave, dealing with the interpretation of the “subject to tax” requirement provided for the application of the Parent-Subsidiary Directive (both Directive 90/435/EEC and Directive 2011/96/EU). Under article 1(1) of Directive…