THE INTRODUCTION OF A MINIMUM EFFECTIVE TAXATION CLAUSE IN THE INTEREST AND ROYALTY DIRECTIVE

Di Gabriele Colombaioni -
I&R Directive-effective-taxation-met-clause-2 I&R Directive-effective-taxation-met-clause-3 The two Room Documents here commented take stock of the discussion and of the conclusions reached so far by the Council (at the relevant time led by the Dutch Presidency) about the proposal to modify the Interest and Royalty Directive (Directive 2003/49/EC, “IRD”) by the introduction of a “minimum effective taxation” (“MET”) clause. Such a proposal is being discussed alongside other actions that the Council, as well as other bodies of the EU, with a view to curb base erosion and profit shifting in the EU context and to keep pace with the work of the OECD in such area. With particul. . .