Loyens & Loeff N.V.in cooperation with MDDP Michalik Dłuska Dziedzic i Partnerzy are pleased to present the publication on the interpretation and application of the General Anti-Avoidance Rule (GAAR) of the Parent-Subsidiary Directive (PSD). This publication follows our previous publication that provided an overview of the measures to prevent abuse of tax treaties and EU Directives in selected countries.
Justyna Bauta-Szostak and Piotr Paśko have prepared Polish part of this report. Issues described in the report will be increasingly important for our clients.
In this publication you may found:
- Implementation of the PSD GAAR
- Legislative developments that may lead to amendments to the existing legislation in the near future
- Relevant court decisions
- Relevant pending court cases / otherwise preliminary references to the CJEU
- Position papers, rulings or administrative guidance issued
- Impact following recent CJEU case law, and more in particular the Danish cases regarding beneficial ownership rendered by the CJEU on 26 February 2019
- Audits being carried out