The Resource Italian withholding tax on internal interest dealings: an EU analysis

Italian withholding tax on internal interest dealings: an EU analysis

Label
Italian withholding tax on internal interest dealings: an EU analysis
Title
Italian withholding tax on internal interest dealings: an EU analysis
Creator
Subject
Language
eng
Summary
Are withholding taxes on interest accruing on internal loans, flowing from an Italian PE to its head office, in harmony with the Interest and Royalty Directive and the ECJ case law? This article looks at (I) the imposition of a withholding tax on internal interest dealings under the Italian tax law, (II) non-applicability of the Interest and Royalty Directive and (III) non-compatibility of the withholding tax with the freedom of establishment
Citation source
In: Tax planning international : European tax service. - London. - Vol. 14 (2012),
http://library.link/vocab/creatorName
  • La Pietra, L
  • Colombaioni, G
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • interest withholding tax
  • intercompany loan
  • Interest and Royalties Directive
  • fundamental freedoms
  • ECJ case law
Label
Italian withholding tax on internal interest dealings: an EU analysis
Instantiates
Publication
Label
Italian withholding tax on internal interest dealings: an EU analysis
Publication

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