The widely divergent rules lead to lengthy, complex and costly withholding tax relief procedures. In some cases, investors end up waiving their right to claim a refund or relief from the withholding tax levied.
Insurance Europe takes the view that substance requirements should be harmonized, and that the Parent-Subsidiary Directive and the Interest and Royalties Directive should be clarified to ensure legal certainty regarding securities and intra-group payments.
Taxpayers and tax authorities require legal certainty as to whether withholding tax benefits that a source state limits to its own resident taxpayers are extended to foreign taxpayers, to avoid discriminatory practices which are against the principle of free movement of capital.
[s|insurance]
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