Pedro Vidal Matos and João Pedro Russo of Cuatrecasas explain how some of the rules governing the levying of stamp duty on intra-group financing may be questioned in light of the standstill clause foreseen in Council Directive 2008/7/EC of February 12 2008, concerning indirect taxes on the raising of capital.
Pedro Vidal Matos of Cuatrecasas reviews the EU Directive on Tax Dispute Resolution Mechanisms. Though far from perfect, it will enhance taxpayer protection and strengthen the EU’s double tax treaty network.