The Corporate Groups and the Problem of the Legal Basis of Tax Liability

Abstract

This paper examines the group of companies and it’s tax liability. For this purpose, it is presupposed the treatment given to the phenomena of the groups by the corporate legislation, as well as the norms from the tax legislation that respect the legal personality as basic unity for the purpose of taxation. Then, it is analyzed based on premises put forward by the Federal Supreme Court the question of the legal base, the possibilities and limits for the tax liability of the group of companies.