These judgments are very important for the practice, because the Supreme Court addressed the applicationof the anti-abuse provision in holding structures.
At first glance, the possible solutions, which have been developed together with the tax (legal) practice, seem to be a good approach to solve the bottlenecks.
The 2025 Spring Memorandum provides insight into the policy themes that the government is grappling with at this time. It also provides a first look at the measures the government plans to take to fin ...
What is of very practical relevance is that the CJEU has ruled that Member States may refuse the participation exemption pursuant to the anti-abuse provision in the Parent-Subsidiary Directive.
