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HMRC internal manual

International Manual

EU Directive: Interest & Royalties paid between Associated Companies - claims and applications by non- residents

List of ‘equivalent taxes’ in other Member States

To qualify for exemption from UK tax a company must be subject to one of the following taxes without being exempt (or to a tax that is identical or substantially similar and which is imposed after the date of entry into force of the Directive). These taxes are identified in Article 3(a)(iii) of the Directive. See also FA2004/S99(3)(b).

Link to list of taxes

To qualify for exemption from UK tax under the terms of the Directive a permanent establishment making a claim/application must, under Article 1(5)(b),“insofar as the payments of the interest or royalties represent income in respect of which it is subject in the Member State in which it is situated be subject to one of the taxes mentioned in Article 3(a)(iii) or in the case of Belgium to the impôt des non-résidents/belasting der niet-verblijfhouders or in the case of Spain to the Impuesto sobre la Renta de no Residentes or to a tax which is identical or substantially similar and which is imposed after the date of entry into force of this Directive in addition to, or in place of, those existing taxes.”