Treaty shopping and other tax arbitrage opportunities in the European Union : a reassessment - part 2

In Part 1 of this article, the author provided a general overview of direct taxation and Community law. She then dealt with specific provisions in the EC Treaty affecting direct taxation. On the basis of the arguments developed in Part 1, in Part 2, the author considers the implications of these arguments by way of four case studies regarding the freedom of establishment of companies and the free movement of capital.