Pregledni rad
https://doi.org/10.32984/gapzh.12.1.10
Directive 2003/49/EC on a Common System of Taxation Applicable to Interest and Royalty Payments Made Between Associated Companies of Different Member States – Analysis of the Directive and the Croatian Transplation of Some Terms from the Directive
Hrvoje Arbutina
; Pravni fakultet Sveučilišta u Zagrebu, Zagreb, Hrvatska
Sažetak
The paper critically analyses translations into Croatian of some terms in the EU Directive on Taxation applicable to interest and royalty payments, namely the term royalty, beneficial owner and permanent establishment. After the analysis, the contents of the Directive are briefly presented. The official translation of EU directives is important because of their implementation in the legal systems of member states and because of the possibility of direct application of directives under certain conditions. In terms of its content, the Directive regulates the distribution of the rights to taxation on investments (in the form of interest and/or royalty payments), conferring the right to taxation on the state of residence of the receiver of interest or royalty payments. This constitutes a considerable departure from the concept of OECD Model agreement on avoidance of double taxation. The terms mentioned in the context of their translation into Croatian are important technical (implementing) elements in the application of the Directive.
Ključne riječi
Directive on interest and royalty payments; royalty; beneficial owner; permanent establishment; European tax law
Hrčak ID:
260603
URI
Datum izdavanja:
16.7.2021.
Posjeta: 1.085 *