The contribution concerns the application of the Interest and Royalty Directive to royalty payments. In particular, it deals with the interpretation of the definition of royalties included in the Directive, discusses the scope of the subject-to-tax requirement provided for in article 3(a)(iii) of the Directive, examines the proper construction of the beneficial owner clause and how instances of abuse of the Directive may be tackled. Moreover the contribution analyses certain procedural issues and concludes with some tax policy considerations
Arginelli, P., Open issues in the application of the Interest and Royalty Directive to royalty payments, in Maisto, G. (ed.), Taxation of intellectual property under domestic law, EU law and tax treaties, International Bureau of Fiscal Documentation, Amsterdam 2018: <<EC AND INTERNATIONAL TAX LAW SERIES>>, 2018/16 51- 94 [http://hdl.handle.net/10807/127466]
Open issues in the application of the Interest and Royalty Directive to royalty payments
Arginelli, Paolo
2018
Abstract
The contribution concerns the application of the Interest and Royalty Directive to royalty payments. In particular, it deals with the interpretation of the definition of royalties included in the Directive, discusses the scope of the subject-to-tax requirement provided for in article 3(a)(iii) of the Directive, examines the proper construction of the beneficial owner clause and how instances of abuse of the Directive may be tackled. Moreover the contribution analyses certain procedural issues and concludes with some tax policy considerations
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