The Instruments in Brief

  • Bernard Jeffcote
Part of the Finance and Capital Markets Series book series (FCMS)


We are concerned in this material only with EC instruments which are either directly addressed at corporate tax issues or which are closely related thereto. For example, the Dividends Directive is clearly in the former category, and the Capital Movements Directive is in the latter category because it has had the direct impact of the introduction of Section 765A ICTA 1988. At the time of writing, the instruments conveniently fall into three groups by reference to their applicability:
  1. (a)

    Five have been adopted by the Council of the EEC and (with the exception of the Transfer Pricing Convention) have been in force from 1 January 1992 or earlier:

  • · The Regulation on the European Economic Interest Grouping (EEIG).

  • · The ‘Capital Movements Directive’.

  • · The ‘Mergers Directive’.

  • · The ‘Dividends Directive’.

  • · The Transfer Pricing Convention.

  • · The ‘Interest and Royalties Directive’.

  • · The ‘Parent/Subsidiary/Losses Directive’.

  • · The ‘Loss Relief Carry-Over Directive’.

  1. (b)

    Two are the newest directives, which it was originally planned should come into force on 1 January 1993:

  • · The ‘Interest and Royalties Directive’.

  • · The ‘Parent/Subsidiary/Losses Directive’.

  1. (c)

    There is one further relevant measure which is still on the shelf. This was proposed by the EC in 1984 with a target adoption date of 1986 and is included here because it has links with some of the other proposals and might eventually see the light of day:

  • · The ‘Loss Relief Carry-Over Directive’.

We have tried above to give the instruments the titles most commonly attributed to them: note that an ‘EEIG’ might often be referred to in conversation as an ‘earwig’, and that the Parent/Subsidiary/Losses Directive does not yet appear to have a widely-used short title, and that we refer to it as the ‘Cross-Border Losses Directive’, because that accurately describes what it is about.

Copyright information

© Ernst & Young 1993

Authors and Affiliations

  • Bernard Jeffcote

There are no affiliations available

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