The New Common Minimum Anti-Abuse Rule in the EU Parent-Subsidiary Directive: Background, Impact Applicability, Purpose and Effect

• Autores: Dennis Weber
• Localización: Intertax, ISSN 0165-2826, Vol. 44, Nº. 2, 2016, págs. 98-129
• Idioma: inglés
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• Dialnet Métricas: 7 Citas
• Resumen

  • Due to an amendment of the Parent-Subsidiary Directive, the EU Member States must include a �common minimum anti-abuse rule� in their legislation for situations that fall under the Parent-Subsidiary Directive (dividend payments between EU subsidiaries and EU parent companies) by 31 December 2015 at the latest.1 With this amendment, it is the first time that it has become mandatory to incorporate a General Anti-Abuse Rule (GAAR) in the tax legislation of the EU Member States. In this paper, I deal with the background, impact, applicability, purpose and effect of the amendment.