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Some may feel that too much attention is being given to the European Arbitration Convention (AC), its basis in Article 293 second indent EC (in the meantime repealed), and its present place in the multinational enterprise tax practice (just a fig leaf). The finding itself that arbitration...
The Damseaux judgment of 16 July 2009 (Case C-128/08) marks the unsuccessful end of the efforts deployed by Belgian taxpayers and by the European Commission (Case C-307/08, Commission v. Belgium, presumably to be dropped shortly) to have Belgium shoulder responsibility (by way of the grant of a...
Abuse of tax law is both a complex and ambiguous concept per se. Added to the fact that each country has its own approach, which entails differing consequences as regards domestic, European community and international tax law, abuse of tax law across Europe may become a real puzzle. A thorough...
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