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Insurance Europe has responded to a consultation conducted by the European Commission on withholding taxes and a new EU system to avoid double taxation.
Insurance Europe welcomes the initiative, as the current rules lead to lengthy, complex and costly withholding tax relief procedures.
Insurance Europe takes the view that substance requirements should be harmonised, and that the Parent-Subsidiary Directive and the Interest and Royalties Directive should be clarified to ensure legal certainty regarding securities and intra-group payments.
Taxpayers and tax authorities require legal certainty as to whether withholding tax benefits that a source state limits to its own resident taxpayers are extended to foreign taxpayers, to avoid discriminatory practices which are against the principle of free movement of capital.