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This article examines the relevance of the 'remaining permanent establishment' requirement under the Merger Directive in the light of the recent jurisprudence of the Court of Justice of the European Union on corporate exit taxes. This requirement is a mechanism meant to ensure that Member States...
This article describes the recent judgment of the Court of Justice of the European Union (the Court) in K. v. Finland. The decision considers a Finnish rule disallowing the deduction of a loss on the sale of property situated in another Member State, when that loss exceeds the amount of foreign...
The Treaty of Maastricht introduced the status of EU citizenship to the nationals of Member States. Central to that status is the right to move and reside freely within the territory of the Member States, in combination with the right to non-discrimination on the ground of nationality. This...
The Common Consolidated Corporate Tax Base (CCCTB) architecture seems to address the major tax design issues relating to foreign business profits in the EU which result from the intrinsic limitations of domestic tax consolidation systems but would intervene in a scenario in which Member States...
The aftermath of the financial crisis of 2008-2009 has seen considerable pressure for financial sector reform, and thus the European Union has decided to go forward with a financial transaction tax ('the FTT'). As disunity between the Member States resulted in enhanced cooperation being resorted...
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