The Principle of Prevention of (Direct Tax) Abuse: Scope and Legal Nature – Remarks on the 3M Italia Case

This article examines the CJEU decision in the 3M Italia case decided on 29 March 2012, which deals with the issue of the EU law compatibility of an Italian tax amnesty provision that allows a taxpayer to pay 5% of the tax at issue in a dispute in exchange for the case being closed where the case has been pending before the courts for at least 10 years.