What is the EU Parent-Subsidiary Directive?

Eliminates withholding tax on dividends paid between EU parent companies (with 10%+ shareholding held at least 1 year) and subsidiaries. Purpose: prevent economic double taxation in the EU single market.

What is the EU Interest and Royalties Directive?

Eliminates withholding tax on cross-border interest and royalty payments between associated EU companies (25%+ shareholding). Replaces treaty rates with 0% for qualifying intra-EU payments.

How do bilateral treaty rates compare?

Common treaty withholding rates on dividends: 5% (qualifying corporate, e.g. Germany-France), 15% (individuals and non-qualifying corporate). Treaty rates on royalties typically 0-10%. Interest often 0% or 5-10%.

What is anti-treaty shopping?

MLI (Multilateral Instrument) and BEPS rules require that treaty benefits only apply to residents who are the beneficial owner of income and are not using intermediate structures primarily to access treaty benefits.

What is the EU ATAD directive?

Anti-Tax Avoidance Directives (ATAD 1 & 2) require all EU states to implement: CFC rules, interest limitation (30% EBITDA), hybrid mismatch rules, exit taxation, and GAAR. Creates minimum standard across EU.

EU Double Tax Treaty Withholding Rate Calculator

Calculate reduced withholding tax rates on dividends, interest, and royalties under EU double tax treaties. EU Parent-Subsidiary Directive: 0% withholding on qualifying intercorporate dividends within EU.

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Frequently Asked Questions

What is the EU Parent-Subsidiary Directive?

What is the EU Interest and Royalties Directive?

How do bilateral treaty rates compare?

What is anti-treaty shopping?

What is the EU ATAD directive?