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The EU Passive Income Tax Directives: A Commentary on the Parent-Subsidiary and Interest-Royalty Directives

The EU Passive Income Tax Directives: A Commentary on the Parent-Subsidiary and Interest-Royalty Directives

Author: Niels Bammens; Filip Debelva
Publisher: Edward Elgar Publishing
ISBN: 9781035334285
Published In: November 2025
Format: Hardback
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

List Price: RMB 1,887.60

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Description
Contents

Details

In this Commentary, expert authors present in-depth analysis of the different provisions of the Parent-Subsidiary Directive (Council Directive 2011/96/EU) and the Interest and Royalty Directive (Council Directive 2003/49/EC). They explore how these directives strengthen the freedom of establishment and the free movement of capital by removing double taxation on dividends, interest, and royalties paid between associated companies, facilitating European integration. Chapters consider the historical evolution of the directives, their interpretation by the Court of Justice, and their practical importance, with specific attention paid to recent developments regarding tax abuse.

Key Features:

Reviews the legislative process and the general objectives of the directives
Provides a detailed article-by-article examination, clarifying procedures, scope, and implementation
Investigates the Court of Justice case law in the context of abuse of the Parent-Subsidiary Directive
Considers the policy underlying the wording of the different provisions and defines core principles, such as relief from double taxation

Practitioners involved in cross-border corporate income taxation in the EU, including tax lawyers and policymakers, will greatly benefit from the book’s practical insights and critical recommendations. It is also an essential resource for students and scholars of European tax law and fiscal policy.

The Parent-Subsidiary Directive: introduction and preamble: 1

Niels Bammens and Filip Debelva

Article 1(1): material scope of application 7

Edoardo Traversa and Fabrizio Pascucci

Article 1(2) – 4: abuse 27

Jean-Philippe Van West

Article 2–3: personal scope of application of the directive 51

Jasper Korving

Article 4: treatment of dividends received 87

Joris Luts and Ward Willems

Article 4(2): hybrid entities and the avoidance of double taxation 127

Félix Daniel Martínez Laguna