Directive 96/2011 / EU (the so-called mother-daughter directive) provides a particularly advantageous regime for companies “mothers” who receive dividends from companies “daughters” resident in an EU member state other than that of residence of the “mother”.
The conventions against double taxation have a fundamental role but often problems arise regarding their applicability when one of the parties involved in an international transaction is to be considered transparent.
Double taxation treaties are treaties that normally only involve two states and provide specific rules on which state is entitled to tax income in all those situations where this income is linked to both states.