Opinion Statement ECJ TF 4/2019 on the ECJ Decision of 26 February 2019 in X-GmbH (Case C-135/17), Concerning the Application of the German CFC Legislation in Relation to Third Countries
HASLEHNER, Werner; García Prats, Alfredo; Heydt, Volkeret al.
CFC rules; substance escape; wholly-artificial arrangements; free movement of capital; Cadbury Schweppes; third countries
Abstract :
[en] This CFE Opinion Statement, submitted to the EU institutions on 12 December 2019, comments on the decision in X-GmbH (Case C-135/17), in respect of which the Court of Justice of the European Union (Grand Chamber) (ECJ) delivered its decision on 26 February 2019. In general terms, the ECJ largely followed the Opinion given by Advocate General Mengozzi on 5 December 2018.
Disciplines :
Tax law European & international law
Author, co-author :
HASLEHNER, Werner ; University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit
Opinion Statement ECJ TF 4/2019 on the ECJ Decision of 26 February 2019 in X-GmbH (Case C-135/17), Concerning the Application of the German CFC Legislation in Relation to Third Countries
Publication date :
April 2020
Journal title :
European Taxation
ISSN :
0014-3138
eISSN :
2352-9199
Publisher :
International Bureau of Fiscal Documentation, Amsterdam, Netherlands
