Payments to an associated EU resident company

For the latest New Development, see ND.1438.

A4.450 Background

ITTOIA 2005, ss 757–767 gave effect to the EU Interest and Royalties Directive 2003/49/EC in respect of payments made by a company resident in the UK or by a UK permanent establishment of an EU state. It provides for the payment of most interest and royalty payments by a UK company or a UK permanent establishment of an EU company to an associated company in an EU member state without deduction of tax.

Following the end of the implementation period for the UK to leave

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