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The Subject-to-Tax Requirement in the EU Parent-Subsidiary Directive (2011/96)

Paolo Arginelli

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Abstract

In this article, the author analyses the requirement in the EU Parent-Subsidiary Directive (2011/96) for a company to be subject to one of the taxes listed in Annex I, Part B of the Directive, without the possibility of an option or of being exempt, or to any other tax that may be substituted for any of those taxes, particularly in light of the recent decision of the Court of Justice of the European Union (ECJ) in Wereldhave (Case C-448/15).

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What this paper is about

In this article, the author analyses the requirement in the EU Parent-Subsidiary Directive (2011/96) for a company to be subject to one of the taxes listed in Annex I, Part B of the Directive, without the possibility of an option or of being exempt, or to any other tax that may be substituted for any of those taxes, particularly in light of the recent decision of the Court of Justice of the European Union (ECJ) in Wereldhave (Case C-448/15).

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OpenAlex reports 7 citations for this work. Citation counts describe recorded attention and do not establish research quality.

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Available abstract

In this article, the author analyses the requirement in the EU Parent-Subsidiary Directive (2011/96) for a company to be subject to one of the taxes listed in Annex I, Part B of the Directive, without the possibility of an option or of being exempt, or to any other tax that may be substituted for any of those taxes, particularly in light of the recent decision of the Court of Justice of the European Union (ECJ) in Wereldhave (Case C-448/15).

Key concepts: Directive, Subject (documents), European court of justice, European union, Business, Law and economics, Economic Justice, Accounting

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