Amendments To The Parent Subsidiary Directive Adopted

March 20, 2015

The EU-Council of Economic and Finance Ministers have adopted the amendments to the Parent Subsidiary Directive, challenging hybrid financial instruments which have the characteristics of both debt and equity.

A payment on hybrid financial instruments could be eligible for tax deduction in the state of source, and at the same time, be tax exempt in the state of residence (double non-taxation). The adopted amendments provide for a mandatory limitation of the exemption in the state of residence, to the extent the (interest) payments are deductible in the state of source.

All EU member states are required to implement the amendments in their domestic legislation no later than 31 December 2015.

Our services?

Read more about our services

View all our services

To your inbox

Stay in the know of the latest accountancy and business news via the KC Newsletter

10 + 7 =

Contact us

Do you have any questions or require our advice? Feel free to contact us

More KC stories

European Union Adopts Black List of 17 jurisdictions
European Union Adopts Black List of 17 jurisdictions

On 5 December 2017, European Union (EU) finance ministers adopted a list of “non-cooperative jurisdictions for tax purposes” also known as  ‘The Black List’. The list is part of the EU's work to counter worldwide tax evasion and avoidance. According to the EU, it will...

read more
Dutch Fiscal Unity Emergency Remedial Measures
Dutch Fiscal Unity Emergency Remedial Measures

On October 25 2017 the Advocate General (“AG”) at the Court of Justice of the European Union (CJEU) published his opinion on the preliminary ruling request of the Dutch Supreme Court in two corporate income tax cases concerning the applicability of the so-called...

read more