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European Union - Final Losses under EU Tax Law: Proposal for a Better Approach

European Union
D. Pezzella
European Taxation, 2014 (Volume 54), No 2/3
30 January 2014
The analysis in this article demonstrates the significant role that the need to preserve a balanced allocation of the power to tax justification plays vis-à-vis the other two justifications taken into account in Marks & Spencer (Case C-446/03): the risk of double use of losses and the risk of tax avoidance. As a consequence, there is a need to identify a narrower concept of final losses that is consistent with the balanced allocation of taxing rights.
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