Judgment_paragraph 51 · Kvaerner plc v Staatssecretaris van Financiën (C-191/99)

51As the United Kingdom Government points out, that choice of criterion also allows the danger of double taxation to be avoided as well as the possibility of tax avoidance, since there is an establishment, and therefore a Member State, corresponding to each risk. On the one hand, no risk can correspond to several establishments and accordingly there can be no double taxation. On the other hand, a policyholder cannot avoid tax liability in a particular Member State, since the existence of an establishment and an insured risk relating to that establishment is linked to objectively verifiable factors.

Kvaerner plc v Staatssecretaris van Financiën (C-191/99)

Key facts

History · 1 version

Connections