9 January 2000

The Allocation of Expenses related to Cross-border Dividend Income covered by the Parent Subsidiary Directive

The survey concluded that the parent subsidiary directive relating to cross-border dividends between EU Member States has been generally successfully implemented throughout the Union.

FEE identified that the lack of an EU-wide tax system penalises unfairly companies operating across borders and receiving dividends from EU subsidiaries. Disallowance of part of the business expenses of the foreign company effectively results in an unjust increase in taxation. In a business situation where operations were solely in one country, business expenses would normally be tax deductible in full. The practice of disallowing a portion of expenses relating to the creation of dividend income does therefore very clearly lead to additional taxation. It is not possible, under current EU tax legislation, to operate a European-wide tax group, other than in rather exceptional circumstances under French law, so no relief is available under a consolidated European style tax system.

Position Paper



Related content

Consultation responseComment letter to the European Commission on Anti-Tax Avoidance Directive

30 May 2016

Consultation responseFEE responds to European Commission’s consultation on improving double taxation dispute resolution mechanisms

15 April 2016

Consultation responseFEE responds to the EC’s public consultation on relaunch of the Common Consolidated Corporate Tax...

8 January 2016

Consultation responseFEE comments on modernising VAT for cross-border e-commerce in the EU

16 December 2015

PublicationFEE issues views on the responsibility of the accountancy profession in tax

16 October 2015

Consultation responseFEE's response to EC's Public consultation on further corporate tax transparency

9 September 2015

Consultation responseFEE comments on the European Commission’s proposal for the mandatory automatic exchange of tax rulings

28 May 2015

PublicationFEE stimulates the tax policy debate in new publication

28 April 2015

Consultation responseFEE responds to OECD Discussion Drafts on the place of supply of business-to-consumer (B2C) services

16 February 2015

Consultation responseFEE comments on OECD Action 6 on base erosion and profit shifting (BEPS)

8 January 2015

PublicationTax Policy: A Matter for Society as a Whole’

2 December 2014

Consultation responseFEE comments on the proposed Council Directive amending EU Directive 2011/96/EU on the common system...

21 March 2014

Consultation responseFEE comments on the proposed Council Directive amending EU Directive 2006/112/EC as regards a standard...

21 February 2014

Consultation responseFEE comments on the VAT legislation on public bodies and tax exemptions in the public...

7 February 2014

Consultation responseFEE comments on EC Consultation on an EU Tax Identification Number

15 May 2013

Consultation responseOn 15 May 2013, FEE issued a comment letter to the EC on the EC...

15 May 2013

Consultation responseOECD International VAT/GST Guide lines – Draft Consolidated Version

16 April 2013

Consultation responseFEE comment letter to the European Parliament’s Economic and Monetary Affairs (ECON) Committee

30 November 2012

Consultation responseFEE Comment letter to the OECD

20 September 2012

Consultation responseEuropean Commission’s Communication on the future of VAT

20 September 2012

Sign up for our newsletter

* indicates required
Would you like to subscribe to our newsletter?
On which topics would you like to receive news?