Design a water gas shift reactor for a hydrogen plant
Sample Solution
The Court did not make the pivotal distinction between two anti-abuse doctrines. The first of these entails prohibiting tax advantages when tax considerations were the only way to determine the taxpayerâs legal behaviour and there was no other credible explanation based on objectively ascertainable facts. The second involves a doctrine in which tax considerations may be the principal (or one of the principal reasons) for explaining the taxpayerâs behaviour. In failing to make this distinction, the Court is seen to interpret the rule of âprincipalâ or âone of the principalâ tax reasons as formulated in Article 11 of the Directive as the expression of the âone and onlyâ doctrine of Cadbury Schweppes. The Court then essentially gave the power of decision making back to the national court. By doing this, it left open the possibility for the national courts to control how the anti-abuse doctrine applied. This in turn gave the Directive provision a âreverse vertical direct effectâ; it allowed the Member State to rely on it against an individual without transposition. 5.4 Acceptance as an overriding principle of EU law Halifax and Koefed provide the framework provide a clear acceptance of the principle of abuse of EU law as a general principle. Thus, 5.5 The influence of Halifax in direct taxation: Cadbury Schweppes and âwholly artificial arrangementsâ Cadbury Schweppes (CS) became the paradigmatic example of the difficulties Member States come up with in order to preserve traditional fiscal systems in a common market contest. Even though CS concerned cross-border issues and the fundamental freedom of establishment, the Court ef>
The Court did not make the pivotal distinction between two anti-abuse doctrines. The first of these entails prohibiting tax advantages when tax considerations were the only way to determine the taxpayerâs legal behaviour and there was no other credible explanation based on objectively ascertainable facts. The second involves a doctrine in which tax considerations may be the principal (or one of the principal reasons) for explaining the taxpayerâs behaviour. In failing to make this distinction, the Court is seen to interpret the rule of âprincipalâ or âone of the principalâ tax reasons as formulated in Article 11 of the Directive as the expression of the âone and onlyâ doctrine of Cadbury Schweppes. The Court then essentially gave the power of decision making back to the national court. By doing this, it left open the possibility for the national courts to control how the anti-abuse doctrine applied. This in turn gave the Directive provision a âreverse vertical direct effectâ; it allowed the Member State to rely on it against an individual without transposition. 5.4 Acceptance as an overriding principle of EU law Halifax and Koefed provide the framework provide a clear acceptance of the principle of abuse of EU law as a general principle. Thus, 5.5 The influence of Halifax in direct taxation: Cadbury Schweppes and âwholly artificial arrangementsâ Cadbury Schweppes (CS) became the paradigmatic example of the difficulties Member States come up with in order to preserve traditional fiscal systems in a common market contest. Even though CS concerned cross-border issues and the fundamental freedom of establishment, the Court ef>
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