The Trade Agreement between the EU and the UK rules out any direct effect. However, the Trade Agreement could have an indirect effect. EU Member States should interpret the capital ownership…
Many States have incorporated General Anti-Avoidance Rules (GAARs) into their tax laws to prevent tax avoidance; within the EU, a GAAR is even mandatory for corporate taxation since 1 January 2019 …
If the UK leaves the EU, this would have immediate consequences for direct taxation.[1] We saw in the first post that the EU fundamental freedoms, EU provisions on State aid and EU directives and…
To withdraw from the European Union, the EU and the UK will need to negotiate a “divorce agreement” (see our first post here). Following this, a so-called Second Agreement could be negotiated between…
The divorce agreement and future gaps in UK law
Divorces are never easy. What will happen after the Brexit? Nobody knows yet. From a legal perspective, article 50 of the Treaty on European Union …
(about the switch-over clause in the ATA Directive)
In order to combat BEPS, the European Commission is proposing to start taxing low taxed non-EU income. That sounds reasonable, but the consequence…
Due to an amendment of the EU Parent-Subsidiary Directive, the EU Member States must include a common minimum anti-abuse provision in their legislation by 31 December 2015 at the latest.
The common…
