De Pietro, Carla
Tax abuse and legal pluralism towards concrete solutions leading to coordination between international tax treaty law and EU tax law / Carla De Pietro .-- , 2020
Resumen.
This article concerns the concept of tax abuse adopted by EU and OECD. The author analyses both the notion of abuse contained in Article 7 (1) of the MLI and the EU notion of abuse as developed by the EU Court of Justice. This analysis shows the existence of discrepancies between these two notions. Furthermore, the article takes into consideration the consequences of this lack of coordination between international tax treaty law and EU tax law.
DERECHO TRIBUTARIO
DERECHO COMUNITARIO EUROPEO
ABUSO DEL DERECHO
FISCALIDAD INTERNACIONAL
ARMONIZACION FISCAL
TRATADOS INTERNACIONALES
EC Tax Review 0928-2750 [print]v. 29, Issue 2, April 2020, p. 84-96
Tax abuse and legal pluralism towards concrete solutions leading to coordination between international tax treaty law and EU tax law / Carla De Pietro .-- , 2020
Resumen.
This article concerns the concept of tax abuse adopted by EU and OECD. The author analyses both the notion of abuse contained in Article 7 (1) of the MLI and the EU notion of abuse as developed by the EU Court of Justice. This analysis shows the existence of discrepancies between these two notions. Furthermore, the article takes into consideration the consequences of this lack of coordination between international tax treaty law and EU tax law.
DERECHO TRIBUTARIO
DERECHO COMUNITARIO EUROPEO
ABUSO DEL DERECHO
FISCALIDAD INTERNACIONAL
ARMONIZACION FISCAL
TRATADOS INTERNACIONALES
EC Tax Review 0928-2750 [print]v. 29, Issue 2, April 2020, p. 84-96