Market leading insight for tax experts
View online issue

Interest and Royalties Directive

 
Graham Airs Slaughter and May in the second of a two-part article discusses the recent Interest and Royalties Directive
 
Given that one of the avowed purposes behind Directive 2003/49/EC (the Interest and Royalties Directive) is to ease the administrative formalities and cash-flow problems to which current arrangements give rise it is surprising and disappointing that Article 1 paragraphs 11 to 16 of the Directive are all concerned with precisely such things.
 
Article 1 paragraph 11 allows the source State to require 'an attestation' that the requirements of the Directive are 'substantiated' at the time that a payment of interest or royalties is made (the reference to those requirements being substantiated at that time supporting the analysis that no exemption is required by the Directive until the qualifying...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
EDITOR'S PICKstar
Top