The Subject-to-Tax Requirement in the EU Parent-Subsidiary Directive (2011/96)

In this article, the author analyses the requirement in the EU Parent-Subsidiary Directive (2011/96) for a company to be subject to one of the taxes listed in Annex I, Part B of the Directive, without the possibility of an option or of being exempt, or to any other tax that may be substituted for any of those taxes, particularly in light of the recent decision of the Court of Justice of the European Union (ECJ) in Wereldhave (Case C-448/15).