Foreseeing the Impact of X GmbH (Case C-135/17), II: A Reasonable Understanding of the PPT Standard under OECD Guidelines and US Case Law
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…