Open issues in the application of the Interest and Royalty Directive to royalty payments

Paolo Arginelli

Research output: Chapter in Book/Report/Conference proceedingChapter

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
Original languageEnglish
Title of host publicationTaxation of intellectual property under domestic law, EU law and tax treaties
EditorsGuglielmo Maisto
Pages51-94
Number of pages44
Volume2018/16
Publication statusPublished - 2018

Publication series

NameEC AND INTERNATIONAL TAX LAW SERIES

Keywords

  • Interest and Royalty Directive

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