European Union - A Comprehensive Analysis of Proposals To Amend the Interest and Royalties Directive – Part 1
- European Union
- S. Martinho Fernandes; R. Bernales; S. Goeydeniz; B. Michel; O. Popa; E. Santoro
- European Taxation, 2011 (Volume 51), No 9/10
- 10 August 2011
In this two-part article, the authors provide a comprehensive analysis of the issues identified in the 2009 Commission report on implementation of the Interest and Royalties Directive, which was based, in part, on an IBFD survey. Part 1 addresses issues concerning the personal scope of the Directive. Part 2 focuses on the Directive's substantive scope and issues of fraud and abuse.