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

Author

Listed:
  • Maarten van 't Riet

    (CPB Netherlands Bureau for Economic Policy Analysis)

  • Arjan Lejour

    (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.

Suggested Citation

  • Maarten van 't Riet & Arjan Lejour, 2019. "Limitation of holding structures for intra-EU dividends: A blow to tax avoidance?," CPB Discussion Paper 406, CPB Netherlands Bureau for Economic Policy Analysis.
    • Handle: RePEc:cpb:discus:406
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    More about this item

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance
    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

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