A Comprehensive Analysis of Proposals To Amend the Interest and Royalties Directive – Part 2

In this two-part article, the authors provide a comprehensive analysis of the issues identified in the 2009 Commission report on implementation of the Interest and Royalties Directive, which was based, in part, on an IBFD survey. Part 1 addressed issues concerning the personal scope of the Directive. Part 2 focuses on the Directive's substantive scope and issues of fraud and abuse.