Die Hinzurechnungsbesteuerung ALS Treaty Override: Zwischen Legitimer Missbrauchsbekampfung Und Unionsrechtsverstoss

»The German Taxation of Controlled Foreign Corporations as a Treaty Override. Between Legitimate Rules against Tax Avoidance Practices and Breach of European Law«: Is the treaty override of § Sec. 20 (1) AStG (still) in conformity with European Union law and what is the significance of the treaty override of the controlled foreign corporation (CFC) if the exercise of taxation rights is secured by the extensive DTA network within the EU and the altered European legal situation? The study systematically identifies the criteria of reliability and system openness of tax systems, which are prerequisites for a defense against abuse in conformity with EU law.