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Record W3205293669 · doi:10.20318/cdt.2021.6263

The concept of abuse in tax matters within European Union law

2021· article· en· W3205293669 on OpenAlex

Why this work is in the frame

A frame that forgets how it found something cannot be audited. These are the routes that admitted this work.

aboutThe title or abstract carries a Canadian signal from the geographic lexicon.
no affNo Canadian affiliation: this work is invisible to an affiliation-only frame.
No Canadian affiliation. An affiliation-only frame, the usual design, would never have seen this work. It is one of the works that make the case for inverting the frame.

Bibliographic record

VenueCUADERNOS DE DERECHO TRANSNACIONAL · 2021
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicTaxation and Legal Issues
Canadian institutionsnot available
Fundersnot available
KeywordsJurisprudenceLawEuropean unionPolitical scienceCommon lawValue (mathematics)Economic JusticeEconomics

Abstract

fetched live from OpenAlex

The principle of prohibition of abuse of rights is applicable in fields as varied as the free movement of goods (judgment of 10 of January 1985, Association des Centres distributeurs Leclerc and Thouars Distribution, Case 229/83), freedom to provide services (judgment of 3 of February 1993, Veronica Omroep Organisatie, Case C‑148/91), public service contracts (judgment of 11 of December 2014, Azienda sanitaria locale n. 5 Spezzino and Others, Case C‑113/13), freedom of establishment (judgment of 9 of March 1999, Centros, Case C‑212/97), company law (judgment of 23 of March 2000, Diamantis, Case C‑373/97), social security (judgments of 2 of May 1996, Paletta, Case C‑206/94; of 6 of February 2018, Altun and Others, Case C‑359/16; and of 11 of July 2018, Commission v Belgium, Case C‑356/15), transport (judgment of 6 of April 2006, Agip Petroli, Case C‑456/04), social policy (judgment of 28 of July 2016, Kratzer, Case C‑423/15), restrictive measures (judgment of 21 of December 2011, Afrasiabi and Others, Case C‑72/11) and value added tax (judgment of 21 of February 2006, Halifax and Others, Case C‑255/02) and, in that sense, the EU principle of prohibition of abuse of law has been developing within the jurisprudence of the Court of Justice of the European Union since the mid-1970s, addressing it in multiple ways, not only in the face of different factual assumptions, which would be understandable and even necessary but, in its evolution, treating asymmetrically the handling of the requirements that must be met to reach the conclusion of the existence of practices abusive.

Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.

Full frame distilled prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.

metaresearch head score (Codex)0.000
metaresearch head score (Gemma)0.000
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Theoretical or conceptual · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: Empirical
Teacher disagreement score0.967
Threshold uncertainty score0.389

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0000.000
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.000
Science and technology studies0.0000.000
Scholarly communication0.0000.000
Open science0.0000.000
Research integrity0.0000.000
Insufficient payload (model declined to judge)0.0000.000

Machine scores (provisional)

The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.

Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.

Opus teacher head0.016
GPT teacher head0.227
Teacher spread0.211 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it