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:

  1. Implementation of the PSD GAAR
  2. Legislative developments that may lead to amendments to the existing legislation in the near future
  3. Relevant court decisions
  4. Relevant pending court cases / otherwise preliminary references to the CJEU
  5. Position papers, rulings or administrative guidance issued
  6. Impact following recent CJEU case law, and more in particular the Danish cases regarding beneficial ownership rendered by the CJEU on 26 February 2019
  7. Audits being carried out