Triangular cases and the Interest and Royalties Directive : untying the Gordian Knot? - part 1

Journal
Gusmeroli, M.
European Union
European Taxation 2005 (Volume 45), No. 1
FormatPDF
EUR
40
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45
(VAT excl.)

This is the first article in a three-part series, which considers the Interest and Royalties Directive in relation to the problems posed by triangular cases. Part 1 commences by recalling the triangular cases issue in a mere tax treaty setting, considering a number of cases in the process. The three parts, in general, focus on PE triangular cases involving interest and royalties.