The CJEU’s ‘Danish beneficial ownership cases’: Tax exemption of dividends under the Parent-Subsidiary Directive and indications of abuse of rights

The Court of Justice of the European Union points to indications of abuse of rights in the failure to meet the requirements for applying the exemption of dividends, as provided for in Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States, when such dividends are earned through a conduit company.