The author discusses the implementation of the 2003/49/EC directive focusing on royalrties taxation. The directive is analyzed and compared to the Double taxation conventions and with the OECD Model art.12. Some pages are dedicated to the anti avoidance provision enshrined in the directive, and namely to the "beneficial ownership" of the royalties for tax purposes.
Taxation of royalties in a EU framework
GREGGI, Marco
2005
Abstract
The author discusses the implementation of the 2003/49/EC directive focusing on royalrties taxation. The directive is analyzed and compared to the Double taxation conventions and with the OECD Model art.12. Some pages are dedicated to the anti avoidance provision enshrined in the directive, and namely to the "beneficial ownership" of the royalties for tax purposes.File in questo prodotto:
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