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If we imagine a Venn diagram of two overlapping circles, A and B, and call the overlapping area C, what can we say about the individual...
Welcome to the European Tax Blog.
Some of Europe's brightest legal minds look at the tax issues across Europe which could impact multinational businesses.
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In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
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There are numerous specific anti-avoidance provisions (SAARs) and the general anti-abuse rule (GAAR), and the Italian tax authorities may...
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There are multiple purpose tests across different parts of the French corporate income tax legislation pursuant to which the French tax...
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Within the Netherlands, there are various anti-abuse or anti-avoidance rules containing purpose tests. Most relevant within the context...
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Germany has a general anti-abuse rule (GAAR) as well as other purpose tests under various specific anti-abuse rules (SAARs) in different...
In addition to the general anti-abuse rule (GAAR), numerous purpose tests are built into the UK tax code. Every time a new set of tax...
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There are multiple purpose test provisions pursuant to which the Portuguese tax authorities can recharacterise or disregard a transaction...
The Spanish tax authorities can challenge transactions under purposes tests in the two different general anti-abuse rules (GAARs) as well...
With Article 7 of the OECD's Multilateral Instrument containing a Principal Purpose Test (or PPT) tax authorities, taxpayers and tax...
At first instance, Euromoney had been decided in favour of the taxpayer and my colleague’s post on the decision surmised that “HMRC may...
For much of last year, Euromoney was paired with Blackrock as a potentially ground-breaking case focusing on a statutory purpose test....