31. März 2022 ECJ: Withholding tax on notional interest in case of interes ... In a Bulgarian case the European Court of Justice (ECJ) held that EU law does not preclude national legislation imposing withholding tax on notional market-based interest (mandated under local tax anti-avoidance rules). Such withholding tax cannot be exempt under the regimes of the IRD (EU Interest - Royalty Directive 2003/49/EC) and the PSD (EU Parent-Subsidiary Directive 2011/96/EU) as there have been no actual payments of interest. Kategorien: European Court of JusticeSchlagwörter: notional tax, interest-free loan, notion ...