United States

Anti-tax avoidance, BEPS, International Tax Law, United States

(University of Michigan)/ /2 Comments

The financial crisis of 2008 and the Great Recession that followed led to millions losing their jobs and their homes. In Europe, the governments reacted to the pressure on the Eurozone by imposing austerity and sharply cutting the social safety net. While the Obama Administration made no such cuts, the size of the US fiscal…

Abuse of law, OECD, Principal purpose test, United States

( PwC Netherlands, Lazarski University and Singapore Management University)/ /Leave a comment

The text represents the personal views of the author, which do not purport to represent the view of Poland’s Ministry of Finance. In the judgement in X GmbH (Case C-135/17), on 26 February 2019, the CJEU for the first time examined a compatibility of CFC rules with the EU primary law to the extent of…