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The growing mobility of persons and capital leads to recovery problems for tax authorities, whose competence is limited to their national territory. Taxpayers may be resident or holding assets in another country than the State where they have tax debts. States may try to overcome these problems...
Direct taxation is the quintessential national prerogative in the EU, although it shall be exercised in conformity with Community law obligations, the European Court of Justice (ECJ) says. The ECJ has upheld the Commission action in reviewing direct business tax rules, directly infringeing...
Double tax conventions (DTCs) generally include clauses that refuse to residents of a contracting state the right to claim treaty benefits with respect to income derived from the other contracting state if they are not ‘beneficial owners’ of the income. ‘Limitation-on-Benefits’ (LOB) clauses in...
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