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Marjaana Helminen

In this chapter, Marjaana Helminen discusses the impact of EU tax law on the tax treatment of passive investment income, such as dividends, interest and royalties. In addition to the two corporate tax directives, that is, the Parent-Subsidiary Directive and the Interest-Royalties Directive, it is explained that the fundamental freedoms have had a huge impact on the powers of Member States to tax cross-border investment income. Despite the large number of cases litigated in these area, there are still many open issues. This chapter discusses these issues both from the perspective of intra-EU situations and from the perspective of situations involving non-Member States.