In June 2017, the European Commission published its proposal on transparency rules for tax planning by intermediaries and certain taxpayers (the Commission proposal). The Commission proposal was amended multiple times, before it was formally adopted as Directive 2018/822 (DAC6) on 25 May 2018. DAC6 requires Member States to put in place, by 31 December 2019,…

The General Court of the European Union has issued two awaited rulings in the Starbucks[1] and Fiat[2] cases. The length and the depth of the analysis made by the judges of the General Court should be acknowledged, even if certain key issues are perhaps too rapidly dealt with. Although the Commission lost in Starbucks, the…