In 2004 the first legal entity applicable in all EU member states, the so-called European Company or Societas Europaea (SE), was introduced in order to strengthen the competi- tiveness of European companies and improve the functioning of the internal market. In or- der for the SE to be an alternative to existing legal forms, the establishment as well as the transfer of seat should not result in tax consequences. However, despite the rules provided by the Merger Directive, the taxation of hidden reserves is still a major concern for com- panies that want to reorganize themselves cross-border. As a consequence, a need for.
