The Parent-Subsidiary Directive18 is aimed at eliminating double taxation on the distribution of profits within corporate groups within the Union. The objective of that directive is, by the introduction of a common system of taxation, to eliminate any disadvantage to cooperation between companies of different member states as compared with cooperation between companies of the same member state and thereby to facilitate the grouping together of companies at Union level.19 It is of considerable importance in the treaty context since it occupies the same ground in many respects as art. 10 (Dividends) and art. 23 (Elimination of Double Taxation) of the OECD Model.20

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