Ashley Greenbank and Martin Zetter consider the growing use of OECD principles in tax reform
The UK has an array of anti-avoidance provisions counteracting perceived or imagined tax advantages arising from arrangements for cross-border profit diversion by both individuals and companies. Initially the potential relevance to these provisions of the fundamental freedoms under EU law in particular the freedom of establishment went unnoticed. However as the years passed it became apparent that the UK’s anti-profit diversion provisions were incompatible with freedom of establishment.
In recent years as a result of lost cases infraction notices and other pressures (in particular the emigration of major international holding companies) the government has...
