Soom, Annika
Double taxation resulting from the ATAD is there relief? / Annika Soom .-- , 2020
Resumen.
This article focuses on the double taxation that is caused by the implementation of the ATAD and identifies the correct source of law, if possible, to provide relief for such double taxation. As the potential sources of law, the OECD MC (OECD Model Tax Convention on Income and on Capital 2017 (Full Version) (OECD Publishing 2019)), and European Union legislation have been analysed. The scope of this article is limited to the rule on interest deduction limitation and controlled foreign company (CFC) rules as provided in the ATAD
ATAD
ELUSION FISCAL
CONTROL
DOBLE IMPOSICION
SOCIEDADES EXTRANJERAS CONTROLADAS
UNION EUROPEA
Intertax 0165-2826v. 48, issue 3, March 2020, p. 273-285
Double taxation resulting from the ATAD is there relief? / Annika Soom .-- , 2020
Resumen.
This article focuses on the double taxation that is caused by the implementation of the ATAD and identifies the correct source of law, if possible, to provide relief for such double taxation. As the potential sources of law, the OECD MC (OECD Model Tax Convention on Income and on Capital 2017 (Full Version) (OECD Publishing 2019)), and European Union legislation have been analysed. The scope of this article is limited to the rule on interest deduction limitation and controlled foreign company (CFC) rules as provided in the ATAD
ATAD
ELUSION FISCAL
CONTROL
DOBLE IMPOSICION
SOCIEDADES EXTRANJERAS CONTROLADAS
UNION EUROPEA
Intertax 0165-2826v. 48, issue 3, March 2020, p. 273-285