Group Taxation within the European Union: Did Papillon and Art. 24(5) of the OECD Model Tax Convention Create a Butterfly Effect?

In this article, the author examines group taxation within the European Union. In particular, the author analyses whether or not the European Court of Justice decision in Papillon and/or Art. 24(5) of the OECD Model Tax Convention oblige Member States to extend the personal scope of their group taxation rules.