Combatting Abuse by Conduit Companies

Journal
Marres, O.C.R.; Groot, I.M. de
European Union
European Taxation 2021 (Volume 61), No. 8
FormatPDF
EUR
40
| USD
45
(VAT excl.)

In this article, the authors address the consequences of EU anti-abuse provisions and the EU anti-abuse principle on conduit companies and the application of tax treaties. Mainly due to the Danish cases, more guidelines are gradually being derived from case law in order to assess whether there is abuse in conduit situations. Those guidelines will probably also be important in applying tax treaties, for various reasons.