European Union - The Role of the Concept of Control under CFC Legislation within the European Union vis-à-vis Third Countries
- European Union
- J. Santos Pinto
- European Taxation, 2013 (Volume 53), No 2/3
- 6 February 2013
This article analyses whether or not a common concept of control exists within the European Union that could be used as a standard both for the European Union and in respect of the domestic controlled foreign company legislation of Member States. The author further examines the implication of such a concept on the free movement of capital vis-à-vis third countries. In this context the article focuses on an analysis of article 82 of the CCCTB Draft Directive.