EU/EEA, Tax Policy

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam, EU Direct Tax Group (EUDTG) PwC)/ /Leave a comment

The Marks & Spencer case (C-446/03), in which the Grand Chamber of the Court of Justice of the European Union rendered its decision that final losses incurred by its non-resident subsidiary can be deducted in the Member State of the resident parent company, caused a commotion. This doctrine is considered to be a violation on…

CCCTB, EU/EEA, OECD, Permanent Establishments

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam, EU Direct Tax Group (EUDTG) PwC)/ /1 Comment

The Anti-Tax Avoidance Directive (ATAD) is the European answer to the phenomenon of BEPS: Base Erosion and Profit Shifting. Characteristically for tax avoidance by Base Erosion and Profit Shifting, is that it takes place within multinational groups (MNE’s). Therefore, the ATAD applies to these groups of companies. Nevertheless, the European Commission has chosen to also…