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Tax Treaty Aspects of the McDonald's State Aid Investigation

18 Pages Posted: 23 May 2017  

Fadi Shaheen

Rutgers, The State University of New Jersey - School of Law, Newark

Date Written: April 24, 2017

Abstract

Supporting the European Commission’s conclusion that Luxembourg was under no treaty obligation to exempt income attributable to a U.S. branch of a McDonald’s Luxembourgian subsidiary, this paper suggests two alternative methods for reaching the same result in ways that avoid possible obstacles in the commission’s approach.

Keywords: International taxation, EU state aid, exemption, double taxation, nontaxation, conflicts of qualification

JEL Classification: H20, H25, H26, K33, K34

Suggested Citation

Shaheen, Fadi, Tax Treaty Aspects of the McDonald's State Aid Investigation (April 24, 2017). Tax Notes International, Vol. 86, No. 4, 2017. Available at SSRN: https://ssrn.com/abstract=2971784

Fadi Shaheen (Contact Author)

Rutgers, The State University of New Jersey - School of Law, Newark ( email )

NJ
United States

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