ECJ Approximation of Laws – Opinion – Request for a preliminary ruling – Directive 2003/49/EC on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States (Interest and Royalties Directive) – Concept of beneficial owner – Acting in one’s own name on behalf of a third party – Effect of the commentaries on the OECD Model Tax Convention on the interpretation of an EU Directive – Abuse of possible fiscal arrangements – Criteria for abuse through avoidance of tax at source – Abuse by taking advantage of a lack of cross-border information – Direct application of a non-transposed provision of a directive – Interpretation of national provisions for the prevention of abuse in conformity with EU law
Citations:
ECLI:EU:C:2018:143, [2018] EUECJ C-115/16 – O
Links:
Jurisdiction:
European
Taxes – Other
Updated: 05 April 2022; Ref: scu.606016
