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European Union - The General Anti-Abuse Rule of the Parent-Subsidiary Directive

Country:
European Union
Author:
F. Debelva; J. Luts
Issue:
European Taxation, 2015 (Volume 55), No 6
Published:
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.
 
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