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 cross-border interest and royalty payments between associated companies within the EU, provided the recipient is the beneficial owner of the income as stipulated in Article 1. It applies to companies linked by a direct minimum holding of 25% for an uninterrupted period of at least two years, and includes anti-abuse provisions to deny benefits in cases of tax evasion, fraud, or abuse.
Pillar: Tax & Transfer Pricing · Authority: Council of the European Union · Version: 1.0.0 · Last updated:
Primary source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32003L0049
SHA-256 integrity: 7befc9078985b3447df0f2b707ef616f34d8b9f14f3ab94093b0e0b033ed1b04
Primary Citations — 7 traced to source
- Council Directive 2003/49/EC, Article 1 - Scope and procedure
- Council Directive 2003/49/EC, Article 2 - Definition of interest and royalties
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