EU: Interest and Royalties Directive
The European Commission has sent a report to the EU Council on the operation of the Interest and Royalties Directive.
The aim of the Directive is to eliminate double taxation on cross-border interest and royalty payments between associated companies.
The Commission has looked at timeliness and completeness of implementation, as well as at issues of interpretation and possible improvements to the existing text, including broadening the scope of the Directive.
The report concludes that while the Directive has generally been implemented in a timely and complete manner, there is a need for guidance and coordination in respect of certain key concepts, as well as scope for improving the current text.
The report is available at http://ec.europa.eu/taxation_customs/resources/documents/common/whats_new/COM(2009)179_en.pdf.