Opinion – Approximation of Laws – Reference for a preliminary ruling – Directive 2011/96 / EU on the common system of taxation applicable to parent companies and subsidiaries of Member States (referred to as the Parent-Subsidiary Directive) – Necessity of an effective beneficiary in the event of dividend payments – Misuse tax adjustment possibilities – Criteria relating to the existence of an abuse committed with the aim of evading taxation at source – Impact of the comments of the OECD model convention on the interpretation of a tax directive European Union – Direct Application of a Non-Transposed Directive Provision – Interpretation in Accordance with EU Law of National Principles for the Prevention of Abuse
Judges:
Kokott AG
Citations:
ECLI:EU:C:2018:145, [2018] EUECJ C-117/16 – O
Links:
Jurisdiction:
European
European
Updated: 06 April 2022; Ref: scu.606035