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The 3D I Case: Useful Clarification from the Court on the Boundaries of the EU Merger Directive

The 3D I Case: Useful Clarification from the Court on the Boundaries of the EU Merger Directive With its judgment in the 3D I case, the Court has issued a useful reminder of the statutory limits of the EU Merger Directive. Although the tax deferral regime provided by the Directive is the standard for corporate reorganizations in the EU, it does not go beyond the temporary non-recognition of gains realized because of reorganization. Most notably, it does not concern the elimination of economic double taxation resulting from the transfer of assets into a corporate subsidiary. http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png EC Tax Review Kluwer Law International

The 3D I Case: Useful Clarification from the Court on the Boundaries of the EU Merger Directive

Rossi-Maccanico
EC Tax Review , Volume 22 (4) – Jun 1, 2013
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Kluwer Law International
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Copyright © Kluwer Law International
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0928-2750
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Abstract

With its judgment in the 3D I case, the Court has issued a useful reminder of the statutory limits of the EU Merger Directive. Although the tax deferral regime provided by the Directive is the standard for corporate reorganizations in the EU, it does not go beyond the temporary non-recognition of gains realized because of reorganization. Most notably, it does not concern the elimination of economic double taxation resulting from the transfer of assets into a corporate subsidiary.

Journal

EC Tax Review – Kluwer Law International

Published: Jun 1, 2013

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