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Werner Haslehner

In this chapter, Werner Haslehner addresses the interaction of State aid law with transfer pricing rules. A number of high-profile investigations into transfer pricing arrangements approved by Member States’ authorities, including for companies such as Amazon, Apple and Starbucks, has sparked fierce debate over the existence of an EU principle of ‘arm’s length’ taxation and its possible content. The chapter examines this debate and issues pertaining to the relationship between State aid law and double taxation treaties, justifications on the basis of providing double tax relief or protection from tax avoidance and the scope of administrative discretion that State aid law needs to accord in such a highly technical area of national law as transfer pricing.

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Werner Haslehner

The ATAD is the most significant EU legislative measure for the harmonization of Member States’ corporate tax law in 30 years. It is also the first piece of EU tax legislation that directly imposes a burden on corporate taxpayers, heralding a paradigm shift in EU direct tax policy, raising fundamental questions of the ATAD’s positioning within the EU Legal Order. These questions concern the EU’s competence to adopt those measures, its relationship with primary EU law, the importance of the ATAD’s scope and objective for the implementation and interpretation of national implementing measures, as well as the wider impact for tax treaties and EU fundamental rights.

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Edited by Christiana HJI Panayi, Werner Haslehner and Edoardo Traversa

Offering a comprehensive exploration of EU taxation law, this engaging Research Handbook investigates the associated legal principles in the context of both direct and indirect taxation. The important issues and debates arising from these general principles are expertly unpicked, with leading scholars examining the status quo as well as setting out a clear agenda for future research.
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Edited by Christiana HJI Panayi, Werner Haslehner and Edoardo Traversa

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Christiana HJI Panayi, Werner Haslehner and Edoardo Traversa

Writing a book on European Union (EU) tax law was never going to be an easy task, not only due to the diversity of areas covered by this subject but also as a result of the fast-paced changes in the area. EU tax law is perhaps one of the most dynamic areas of EU law. Notwithstanding de minimis harmonisation, for direct taxation, and more extensive framework-style harmonisation, for indirect taxation, the combined effect of the Commission’s integrationist leanings with taxpayer proactiveness and the pursuit of litigation has led to the development of an impressive array of legal principles. Being supreme law, these principles permeate domestic tax systems and shape domestic tax rules, in variable intensities and with variable preemptive effects.

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Edited by Werner Haslehner, Katerina Pantazatou, Georg Kofler and Alexander Rust

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Edited by Werner Haslehner, Katerina Pantazatou, Georg Kofler and Alexander Rust

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Edited by Werner Haslehner, Katerina Pantazatou, Georg Kofler and Alexander Rust

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Edited by Werner Haslehner, Katerina Pantazatou, Georg Kofler and Alexander Rust

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WERNER HASLEHNER, KATERINA PANTAZATOU, GEORG KOFLER, ALEXANDER RUST

This book provides a concise, practical guide to the European Union’s Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD’s five specific anti-avoidance rules, its chapters explain the background of those rules, the directive’s interactions with relevant jurisprudence, and the challenges posed to the ATAD’s interpretation and implementation in domestic law.