European Tax Blog

6/26/2025 2:22:28 PM

Vietnamese jets and double tax treaties

By Max Cheung

What can an aircraft leasing case tell us about the interpretation of tax treaties? Quite a bit, as it turns out. In VietJet Aviation,...

9/1/2023 1:18:12 PM

Looking at the bigger picture: CGT planning and the purpose test in the reorganisation rules

By Tanja Velling

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...

7/31/2023 9:41:48 AM

Purpose tests in anti-abuse or anti-avoidance provisions: perspectives across Europe

By Stefano Brunello Dormal Victor Camatta Mees Vergouwen +4 more...

In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...

7/31/2023 9:41:23 AM

Purpose tests in anti-abuse or anti-avoidance provisions in Italy

By Stefano Brunello Dormal Umberto Lorenzi

There are numerous specific anti-avoidance provisions (SAARs) and the general anti-abuse rule (GAAR), and the Italian tax authorities may...

7/31/2023 9:40:20 AM

Purpose tests in anti-abuse or anti-avoidance provisions in France

By Pierre-Henri Durand Victor Camatta

There are multiple purpose tests across different parts of the French corporate income tax legislation pursuant to which the French tax...

7/31/2023 9:39:58 AM

Purpose tests in anti-abuse or anti-avoidance provisions in the Netherlands

By Mees Vergouwen Frank Potgens Wiebe Dijkstra

Within the Netherlands, there are various anti-abuse or anti-avoidance rules containing purpose tests. Most relevant within the context...

7/31/2023 9:39:33 AM

Purpose tests in anti-abuse or anti-avoidance provisions in Germany

By Jan Adami

Germany has a general anti-abuse rule (GAAR) as well as other purpose tests under various specific anti-abuse rules (SAARs) in different...

7/31/2023 9:39:11 AM

Purpose tests in anti-abuse or anti-avoidance provisions in the UK

By Tanja Velling

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...

7/31/2023 9:38:46 AM

Purpose tests in anti-abuse or anti-avoidance provisions in Portugal

By Marta Pontes Gonçalo Martins Agostinho

There are multiple purpose test provisions pursuant to which the Portuguese tax authorities can recharacterise or disregard a transaction...

7/31/2023 9:38:13 AM

Purpose tests in anti-abuse or anti-avoidance provisions in Spain

By Víctor Viana Teresa Morales Marta Hernández-Mora Olivié

The Spanish tax authorities can challenge transactions under purposes tests in the two different general anti-abuse rules (GAARs) as well...

8/31/2022 11:28:46 AM

Taxpayer wins double tax treaty purpose test case

By Mike Lane

With Article 7 of the OECD's Multilateral Instrument containing a Principal Purpose Test (or PPT) tax authorities, taxpayers and tax...

8/9/2022 12:51:27 PM

Euromoney: Taxpayer prevails before the Upper Tribunal

By Tanja Velling

At first instance, Euromoney had been decided in favour of the taxpayer and my colleague’s post on the decision surmised that “HMRC may...

4/16/2021 12:00:00 AM

The long-awaited Euromoney decision has finally appeared. But is it right?

By William Watson

For much of last year, Euromoney was paired with Blackrock as a potentially ground-breaking case focusing on a statutory purpose test....