Double taxation resulting from the ATAD is there relief? Annika Soom
By: Soom, Annika
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Material type: 
ArticlePublisher: 2020Subject(s): ATAD | ELUSION FISCAL | CONTROL | DOBLE IMPOSICION | SOCIEDADES EXTRANJERAS CONTROLADAS | UNION EUROPEA
In:
Intertax v. 48, issue 3, March 2020, p. 273-285Summary: 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
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2020/3-2 (Browse shelf) | Available | OP 2141/2020/3-2 |
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| OP 2141/2020/1-7 UN MTC Article 8 | OP 2141/2020/3 Intertax | OP 2141/2020/3-1 Lost in construction | OP 2141/2020/3-2 Double taxation resulting from the ATAD | OP 2141/2020/3-3 Special tax zones and State aid rules | OP 2141/2020/3-4 A new taxing right for the market jurisdiction | OP 2141/2020/3-5 Global enterprise taxation (GET) |
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
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