Taxation – Corporation tax – Transfer of an interest in a partnership to a capital company – Book value – Value as part of a going concern – Agreement on the prevention of double taxation – Immediate taxation of unrealised capital gains – Different treatment – Restriction on free movement of capital – Preserving the balanced allocation of powers to impose taxes between the Member States – Proportionality
C-164/12, [2014] EUECJ C-164/12, [2014] BTC 16, [2014] 2 CMLR 47, ECLI:EU:C:2014:20, [2014] STC 1345
Bailii
European, Corporation Tax
Updated: 29 November 2021; Ref: scu.520796