000			01443nab a2200229 c 4500
999			_c142519 _d142519
003			ES-MaIEF
005			20200907160803.0
007			ta
008			200907s2020 ne ||||| |||| 00| 0 eng d
040			_aES-MaIEF _bspa _cES-MaIEF
041	0		_aspa
100	1		_958101 _aStevens, Stan
245	0	0	_aEvaluation of the earnings stripping rules _c Stan Stevens
260			_c2020
504			_aBibliografía
520			_aMember States had to have implemented the anti-earnings stripping rules by 1 January 2019. In this article these rules are evaluated from an economic and EU law perspective. The author concludes that the rules are probably not in breach of EU law because they are implemented without distinction between domestic and cross border situations. In addition there is little room to assess rules which are the result of (full) harmonization. Nevertheless some risks exist in particular with regard to the interaction between the group regimes and the earning stripping rules and the design of the standalone exception. An important drawback of the earnings stripping rules is the risk of double taxation. This could have been avoided by the EU legislator.
650			_aIMPUESTOS _947460
650		4	_aAMPLIACION DE CAPITAL _925734
650		4	_aLEGISLACION COMUNITARIA _942805
773	0		_9162938 _oOP 2141-B/2020/4 _tEC Tax Review _w(IEF)124968 _x0928-2750 [print] _gvolume 29, issue 4, august 2020, p. 158-177
942			_cART