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- Title
ATAD III und Ansässigkeit.
- Authors
Haase, Florian
- Abstract
The article deals with the issue of the residency of partnerships in connection with the planned Unshell Directive to prevent tax abuse through mailbox companies. Problems with the application of the directive to partnerships are discussed and the imprecise definition of the term "residency" is criticized. The comparability of associations of persons with corporations for tax purposes is addressed, and the distinction between transparent and opaque entities is emphasized. The question is raised whether transparent entities should be treated equally in terms of residency and which state decides on residency. The application of the directive to the joint tax system of parent and subsidiary companies from different member states is also discussed, and the need for clarification and revision of the draft directive is emphasized.
- Subjects
CORPORATE purposes; CORPORATE taxes; PARENT companies; SUBSIDIARY corporations; MAILBOXES
- Publication
Die Unternehmensbesteuerung (Ubg), 2024, Vol 17, Issue 6, p301
- ISSN
1865-7222
- Publication type
Article
- DOI
10.9785/ubg-2024-170601