What Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States requires
This Directive eliminates withholding taxes on interest and royalty payments between associated companies in different EU Member States, provided the beneficial owner is a qualifying associated company and the arrangement is not abusive under Article 5. It applies to companies resident in EU Member States with a minimum 25% direct or indirect ownership.
Pillar: Tax & Transfer Pricing · Authority: European Parliament and Council of the European Union · Version: 1.0.1 · Last updated:
Primary source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32003L0049
SHA-256 integrity: cecd6ca385cb55b5a7dfa0a3621bce5124734ae97732afab61d33ec263fbf656
Primary Citations — 7 traced to source
- Council Directive 2003/49/EC, Article 2(1) - Definition of Associated Companies and Minimum Ownership Threshold
- Council Directive 2003/49/EC, Article 2(2) - Definition of Interest Payments
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