Group Taxation Regimes Across the European Union: A Domestic Tax Regime Beyond Borders?

In this note, the author discusses the impact of the freedom of establishment on group taxation rules across several EU Member States (France, Luxembourg and the Netherlands), in light of the recent ECJ decision in Manitou BF (C-407/22), as well as older ECJ case law. It also discusses practical examples that demonstrate the value of group taxation rules for taxpayers amid European and international tax developments.