The Prohibition of Abuse of Rights after the ECJ Danish cases
Analysis of the ECJ judgments, reading by national courts, and impact on tax treaty practice Authors: Robert Danon,[1] Daniel Gutmann,[2] Margriet Lukkien,[3] Guglielmo Maisto,[4] Adolfo Martín...
View ArticleEqiom: alive and kicking
Legend has it that a medieval hero of Spain, the Castilian knight El Cid, won a battle after death when his wife strapped his dead body to his horse, knowing that his reputation as an invincible...
View ArticleWhere is a person “established”?
Territorial connection (or its more fashionable name “nexus”) for tax purposes is expressed in a variety of ways in domestic and international legal instruments. Permanent establishment in article 5 of...
View ArticleVAT Fixed establishment = permanent establishment? or, should direct and...
The very recent CJEU judgement in Berlin Chemie A. Menarini v Administraţia Fiscală pentru Contribuabili Mijlocii Bucureşti (Case C-333/20) ECLI:EU:C:2022:291, admirably examined by Giorgio Beretta...
View ArticleA statute for European cross-border associations and non-profit...
As it currently stands, the legal and policy framework for non-profit organisations and foundations within the European Union differ – in some cases slightly, in others significantly. This regularly...
View ArticleDAC6 Directive and Attorneys’ Professional Secrecy: Analysis of the Opinion...
A Critical Analysis under European, French and Belgian Law[1]. Part I : The incompatibility with European, French and Belgian Law of precluding the protection under Article 47 of the Charter for...
View ArticleDAC6 Directive and Attorneys’ Professional Secrecy: Analysis of the Opinion...
A Critical Analysis under European, French and Belgian Law[1] Part II : The legal professional privilege in the common constitutional tradition and the requirements under Article 52 of the Charter...
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