What Council Directive 2011/96/EU of 16 November 2011 on the common system of taxation applicable to parent companies and subsidiaries of different Member States requires
This Directive eliminates withholding taxes on dividends paid between qualifying parent companies and subsidiaries within the EU, provided the parent holds at least 10% of the subsidiary’s capital for an uninterrupted period of at least one year, and the arrangement does not constitute abuse under the general anti-abuse rule (GAAR) in Article 5. It applies to EU-resident corporate entities in cross-border group structures.
Pillar: Tax & Transfer Pricing · Authority: European Commission · Version: 1.0.0 · Last updated:
Primary source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32011L0096
SHA-256 integrity: de5a3352c33f0ee8804481cd0fbc4ea4252e278d7a2f16ae47a4103dc963e6c0
Primary Citations — 5 traced to source
- Council Directive 2011/96/EU, Article 4(1) - Exemption from withholding tax on dividends paid by a subsidiary to its parent company
- Council Directive 2011/96/EU, Article 4(2) - Minimum holding period of one year for the 10% capital participation
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