Limitation of holding structures for intra-EU dividends: A blow to tax avoidance?

Maarten van 't Riet () and Arjan Lejour
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Maarten van 't Riet: CPB Netherlands Bureau for Economic Policy Analysis

No 406, CPB Discussion Paper from CPB Netherlands Bureau for Economic Policy Analysis

Abstract: This article analyses the recent rulings from the European Court of Justice in two Danish cases and examines their possible impact on international tax avoidance. These rulings regard limitations of tax benefits related to cross-border dividends and interest payments resulting from the interposition of holding companies in the EU. We conclude that from a legal perspective, the rulings demonstrate the alignment of international tax policies to combat tax avoidance between the EU and the OECD. This article analyses the recent rulings from the European Court of Justice in two Danish cases and examines their possible impact on international tax avoidance. These rulings regard limitations of tax benefits related to cross-border dividends and interest payments resulting from the interposition of holding companies in the EU. We conclude that from a legal perspective, the rulings demonstrate the alignment of international tax policies to combat tax avoidance between the EU and the OECD.

JEL-codes: F23 H25 H26 H32 (search for similar items in EconPapers)
Date: 2019-12
New Economics Papers: this item is included in nep-eur and nep-pbe
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Persistent link: https://EconPapers.repec.org/RePEc:cpb:discus:406

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