In this article, the author discusses the different ways the Court of Justice of the European Union (CJEU) applies the concept of neutralization in the area of withholding taxes on the one hand and in the area of personal allowances on the other hand. She also discusses recent case law developments in the area of personal allowances. In conclusion, the author explains why the CJEU has adopted different approaches to this issue and presents what she believes would be an accurate and consistent approach.
Intertax