ECJ Opinion – Freedom of movement of persons – Freedom of establishment – Law on controlled foreign companies – Attribution to the parent company of the profits of its subsidiary established in another Member State as those profits arise – Obstacle – Justification – Counteraction of tax avoidance.
Judges:
Leger AG
Citations:
[2006] STC 1908, [2006] EUECJ C-196/04, [2006] EUECJ C-196/04O
Links:
Jurisdiction:
European
Cited by:
Cited – Revenue and Customs v Pendragon Plc and Others SC 10-Jun-2015
‘This appeal is about an elaborate scheme designed and marketed by KPMG relating to demonstrator cars used by retail distributors for test drives and other internal purposes. In the ordinary course, a car distributor will buy new cars for use as . .
Lists of cited by and citing cases may be incomplete.
Taxes Management
Updated: 01 September 2022; Ref: scu.241418
