Why this book?

This study discusses the impact of the EC Treaty on the recognition of entities in the internal market.

The EC Treaty envisages the internal market as an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured in accordance with the provisions of the EC Treaty.

One of the key questions discussed in this study is how this rationale reflects the relation between tax laws of Member States and, specifically, the relation between the application of autonomous classification methods by Member States and the free allocation of economic resources in the internal market.

This study also contains an examination of how the different approaches to hybrid entities in tax treaties interfere with EC law. This part of the study contains an analysis of how the interrelation between domestic (tax) laws and the approach to classification conflicts under existing bilateral tax treaties relates to EC law.

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This book is part of the IBFD Doctoral Series

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Author(s)

Gijs Fibbe works at PricewaterhouseCoopers Rotterdam and teaches international tax law at the Law Faculty of the Erasmus University of Rotterdam.

Winner of the 2009 Mitchell B. Carroll Prize. Awarded by the International Fiscal Association (IFA).