Partnerships and other hybrid entities and the EC Corporate Direct Tax Directives

The purpose of this article is to demonstrate how the EC Directives on direct corporate taxation deal with the issues arising from the use of partnerships and other hybrid entities in an EC context and to highlight some of the unresolved problems. The article, therefore, considers and comments on the provisions in the EC Parent-Subsidiary, the Interest and Royalties and the EC Merger Directives in relation to this topic.