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<p>This paper sets out to analyse obligations under EU law (Art. 49&#xa0;TFEU) to grant tax benefits linked with group taxation outside profit and loss consolidation to cross-border groups that have not entered into a group taxation arrangement. The analysis is based on the example of Norwegian group taxation. The study examines the current case law of the ECJ and the EFTA Court. The tax implications for the Member States concerned are highlighted. Furthermore, the study proposes avenues for the legal structuring of group taxation legislation in accordance with EU law.</p>

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Group Taxation and EU Law

  • 期刊论文

  • 出版模式：

    开放获取

  • 发表日期：

    2025年5月27日

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  • Thomas Kollruss

摘要

This paper sets out to analyse obligations under EU law (Art. 49 TFEU) to grant tax benefits linked with group taxation outside profit and loss consolidation to cross-border groups that have not entered into a group taxation arrangement. The analysis is based on the example of Norwegian group taxation. The study examines the current case law of the ECJ and the EFTA Court. The tax implications for the Member States concerned are highlighted. Furthermore, the study proposes avenues for the legal structuring of group taxation legislation in accordance with EU law.