2.4.1 Introduction

The first part of this chapter has established the framework conditions for a group concept from an economic perspective. In order to arrive at a treaty-based definition of the notion of a group, the following section explains existing group concepts from various perspectives. The goal is to add additional elements to the economic group concept established in the previous section, through inspiration from existing systems.

Par. 2.4.2 deals with the group concept as reflected in the OECD MTC and related sources. Par. 2.4.3 discusses the definitions of the group concept as included in European directives and draft directives in the field of direct taxation. Par. 2.4.4 describes the highlights of group concepts used in national group taxation regimes. Subsequently, a number of observations is made in par. 2.4.5. Par. 2.4.6 ends this section with a brief conclusion.