May linking rules related to hybrid financial instruments be incompatible with the EU Fundamental freedoms? And with Article 24 (4) OECD MC? What about treaty override?
It is no secret that hybrid…
In June 2017, the European Commission published its proposal on transparency rules for tax planning by intermediaries and certain taxpayers (the Commission proposal). The Commission proposal was…
The General Court of the European Union has issued two awaited rulings in the Starbucks[1] and Fiat[2] cases. The length and the depth of the analysis made by the judges of the General Court should…
