(1) Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States, which was repealed by Council Directive 2011/96/EU of 30 November 2011
(2) Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States.
(3) The global dimension, highlighted by extensive work in the OECD/G20, is documented in detail in the Staff Working Document.
(4) COM(2014) 902 final of 28.11.2014, p. 15.
(5) See Annex 4 in the Staff Working Document, regarding links with the OECD BEPS project.
(6) See Annex 4 in the Staff Working Document, identifying links between the actions and ongoing OECD work in the BEPS project.
(7) Parent-Subsidiary Directive and Interest and Royalties Directive
(8) Changes to the definition of Permanent Establishment (PE) are being developed at international level, to prevent the artificial avoidance of PE status in relation to BEPS, including through the use of commissionaire arrangements and the specific activity exemptions.
(9) Internationally, work is underway to address BEPS using controlled foreign company (CFC) rules. Many countries already have CFC rules, but these rules do not always counter BEPS in a comprehensive manner.
(10) http://www.oecd.org/ctp/beps-action-5-agreement-on-modified-nexus-approach-for-ip-regimes.pdf
(11) For example, see responses to the public consultation on Double Tax Conventions and the Internal Market http://ec.europa.eu/taxation_customs/common/consultations/tax/2010_04_doubletax_en.htm
(12) C(2012)8806 and C(2012)8805
(14) The European Commission successfully concluded a dialogue on company tax issues with Switzerland which initiated the removal of five CH tax regimes which were considered harmful. A similar dialogue is currently ongoing with Liechtenstein and Mauritius.
(15) https://ec.europa.eu/eusurvey/further-corporate-tax-transparency-2015/management/test
