Fundamental freedoms, intra-group loans and the fight against tax avoidance: the Court of Justice clarifies the Lexel case doctrine

In the Judgment of 4 October 2024, X BV (C-585/22), the Court of Justice clarifies the position adopted in the Lexel case (C-484/19) and concludes that compliance with the arm’s length principle does not protect intra-group transactions that do not reflect economic reality from being categorised as a wholly artificial arrangement.

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