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Previous	OP 2141-B/2006/1-3 M&S judgment	OP 2141-B/2006/1-4 Treatment of permanent establishments and subsidiaries under EC law	OP 2141-B/2006/1-5 The European Court of Justice's solution to aggressive VAT planning	OP 2141-B/2006/2-1 Mark and Spencer v Halsey ( HM Inspector of Taxes )	OP 2141-B/2006/2-2 Tax treaties between Member States and Third States	OP 2141-B/2006/2-3 The different translations of the term " company " in the Merger Directive and the Parent - Subsidiary Directive	OP 2141-B/2006/3-1 The impact of the Swiss - EC Agreement on intra - group dividend, interest and royalty payments	Next

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Biblioteca del Instituto de Estudios Fiscales

Mark and Spencer v Halsey ( HM Inspector of Taxes ) restriction, justification and proportionality Tom O'Shea