Mario Tenore's scientific contributions

Publications (2)

Article
The article aims at achieving consistency in the case law of the European Court of Justice (ECJ) on the taxation of dividends from the perspective of the Home State and that of the Host State. Based on the assumption that EU Member States are obliged to ensure the neutrality with regard to inbound dividends and outbound dividends, the author demons...
Article
The article provides a thorough analysis of some selected issues both in the framework of Article 10 OECD Model Convention (OECD MC) and of the Parent-Subsidiary Directive. On a comparative basis, the analysis covers amongst others the definition of ‘company’, the definition of ‘capital’, the type of income covered, the definition of residence and...