Die Vereinbarkeit der ATAD mit europäischem Recht am Beispiel der Hinzurechnungsbesteuerung

'The Compatibility of the ATAD with European Law. CFC-Rules: Conformity with EU Law and Issues of Application': This thesis examines the compatibility of the Anti-Tax Avoidance Directive (ATAD) with European law, using the regime of Controlled Foreign Company (CFC) taxation as its central case study. It demonstrates the extent to which the EU, in enacting the ATAD, acted beyond the scope of its conferred competences, and argues that the Directive infringes upon the principle of subsidiarity, the freedom of establishment, and the free movement of capital. The ATAD is characterized as an ultra vires legal act, and the resulting implications for national law are set forth.