European Union - Tackling Deduction and Non-Inclusion Schemes – The Proposal of the European Commission
- European Union
- C. Marchgraber
- European Taxation, 2014 (Volume 54), No 4
- 7 March 2014
On 25 November 2013, the European Commission released a proposal for a council directive amending the Parent-Subsidiary Directive (2011/96). The objective is, inter alia, to eliminate double non-taxation resulting from, on the one hand, the non-inclusion of dividends and similar profit distributions received by a company of a Member State and, on the other hand, the deductibility of such payments at the level of the paying company resident in another Member State. This article analyses whether or not the proposal lives up to its promise.