How Should EU Member States Implement the Recommendations Following from the OECD BEPS Project? – A Comment to the Recently Published Discussion Draft on Action 3
It is well known that case law from the European Court of Justice (ECJ) imposes limitations on the application of anti-avoidance rules by Member States. Accordingly, it is of vital importance that recommendations made under the OECD project on base erosion on profit shifting (the BEPS project), are adaptable, where necessary, to enable Member States…