European Union - Transfer of Residence within the European Union: The Treatment of Pre-Existing Losses – Part 1
- European Union
- A. Rivolta
- European Taxation, 2010 (Volume 50), No 1
- 14 December 2009
In this two-part article, the treatment of pre-existing losses upon a transfer of residence within the European Union is discussed. In Part 1, EC law concepts, the ideal versus actual tax treatment and ECJ case law regarding treatment in the departure state are considered. Part 2 focuses on ECJ case law regarding the arrival state, secondary EC law and possible solutions to the issues discussed.