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 ...
05. März 2013 Maximum foreign tax credit should not be reduced by domestic ... The ECJ has held that the notional tax on foreign source income should not be reduced by a portion reflecting domestic allowances and reliefs. Kategorien: From EuropeSchlagwörter: foreign tax credit, foreign tax relief, ...
