What the new horizontal tax consolidation regime may mean for private equity sponsors, multinational groups, financial institutions (and everyone else…).
In June 2014, the European Court of Justice (ECJ) ruled that the Dutch fiscal unity regime rules had breached European Union (EU) law because, inter alia, the rules did not allow a fiscal unity between two Dutch “sister” companies held by a common parent company based in the EU/European Economic Area (EEA). As a reaction to such ECJ decisions, several EU countries — including Spain — have amended and extended their tax consolidation regimes in order to prevent challenges to their own rules before the ECJ.
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