European Union - The General Anti-Abuse Rule of the Parent-Subsidiary Directive
- European Union
- F. Debelva; J. Luts
- European Taxation, 2015 (Volume 55), No 6
- 15 May 2015
With the adoption of a new general anti-abuse rule in the EU Parent-Subsidiary Directive (2011/96), the EU legislator has reinforced the position of EU Member States in countering abusive practices. This is the second amendment in a short period, which follows the adoption of the “anti-hybrid” provision. In this article, the authors discuss the new general anti-abuse rule and its interplay with other (domestic and treaty-based) anti-abuse rules.