Tax Treaty Aspects of the McDonald's State Aid Investigation
18 Pages Posted: 23 May 2017
Date Written: April 24, 2017
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: Suggested Citation