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High Level Working Party Recommends Suspending Technical Work on EU Interest and Royalties Directive

28 June 2016

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Proposed Changes

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European Union

The EU Council's High Level Working Party on Tax Questions (HLWP) has reportedly recommended suspending technical work on amendments to the EU Interest and Royalties directive (2003/49/EC) in a June 23 report to the European Council. Under the Directive, group interest and royalty payments between member states are exempt from withholding tax subject to certain conditions. The HLWP work concerns amendments to the Directive to expand the scope of eligibility while introducing certain subject-to-tax conditions, which include a clause on minimum effective taxation (MET) on its own or in combination with an economic activity test (possibly based on OECD nexus...