The recent judgment of the ECJ in the Athinaiki case has possible implications
outside its reference country of Greece. This article looks at how the decision could affect the tax systems of five other member states: the UK, France, Germany, Belgium and the Netherlands. By Patrick Tardivy, Martin Schiessl, Axel Haelterman, Michiel Sunderman and Roger Berner of Freshfields Bruckhaus Deringer in Paris, Frankfurt, Brussels and Amsterdam
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While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort