EU - Hybrid loan arrangements within corporate groups 

July 8: The European Commission today announced that the Economic and Financial Affairs Council formally adopted an amendment to EU tax rules that will prevent the double non-taxation of dividends distributed within corporate groups deriving from hybrid loan arrangements.

Read the EC release [PDF 102 KB]


The amendment to the Parent-Subsidiary Directive will prevent cross-border companies from planning their intra-group payments so as to result in double non-taxation when hybrid loan arrangements are involved. The EU Member State of the parent company will refrain from taxing profits from the subsidiary only to the extent that such profits are not tax deductible for the subsidiary.


The EU Member States will have until 31 December 2015 to transpose the amendment into national law.




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