council direct ec june taxat save incom form interest payment council european union regard treati establish european commun articl thereof regard propos commiss regard opinion european parliament regard opinion european econom social committe articl treati guarante free movement capit save incom form interest payment debt claim constitut taxabl incom resid member state virtu articl treati member state appli relev provis tax law distinguish taxpay situat regard place resid regard place capit invest requisit measur prevent infring nation law regul field taxat accord articl treati provis member state tax law design counter abus fraud constitut mean arbitrari discrimin disguis restrict free movement capit payment establish articl treati absenc coordin nation tax system taxat save incom form interest payment treatment interest receiv resid concern resid member state avoid form taxat member state resid interest receiv member state situat creat distort capit movement member state incompat intern market direct build consensu reach santa maria da feira european council june subsequ ecofin council meet novemb decemb januari ultim aim direct enabl save incom form interest payment made member state benefici owner individu resid member state made subject effect taxat accord law member state aim direct achiev target interest payment made secur econom oper establish member state benefit benefici owner individu resid member state object direct suffici achiev member state lack coordin nation system taxat save incom achiev commun level commun adopt measur accord principl subsidiar set articl treati accord principl proportion set articl direct confin minimum requir order achiev object purpos pai agent econom oper pai interest secur payment interest benefit benefici owner defin notion interest payment pai agent mechan refer made council direct eec decemb coordin law regul administr provis relat undertak collect invest transfer secur ucit scope direct limit taxat save incom form interest payment debt claim exclus inter alia issu relat taxat pension insur benefit ultim aim bring effect taxat interest payment benefici owner member state resid tax purpos achiev exchang inform interest payment member state council direct eec decemb mutual assist compet author member state field direct indirect taxat basi member state exchang inform tax purpos incom cover direct continu appli exchang inform addit direct direct derog automat exchang inform member state interest payment cover direct make effect taxat payment benefici owner member state resid tax purpos accord nation law state stipul member state exchang inform pursuant direct permit reli limit exchang inform set articl direct eec view structur differ austria belgium luxembourg appli automat exchang inform time member state transit period withhold tax ensur minimum level effect taxat rate increas progress member state appli withhold tax save incom cover direct order avoid differ treatment austria belgium luxembourg oblig appli automat exchang inform swiss confeder princip andorra princip liechtenstein princip monaco republ san marino ensur effect exchang inform request payment interest member state transfer greater part revenu withhold tax member state resid benefici owner interest member state provid procedur allow benefici owner resid tax purpos member state avoid imposit withhold tax authoris pai agent report interest payment present certif issu compet author member state resid tax purpos member state resid tax purpos benefici owner ensur elimin doubl taxat interest payment result imposit withhold tax accord procedur laid direct credit withhold tax amount tax due territori reimburs benefici owner excess amount tax withheld appli tax credit mechan grant refund withhold tax order avoid market disrupt direct transit period appli interest payment negoti debt secur direct preclud member state levi type withhold tax refer direct interest aris territori long unit state america switzerland andorra liechtenstein monaco san marino relev depend territori member state appli measur equival provid direct capit flight countri territori imperil attain object direct appli date countri territori appli measur commiss report year oper direct propos council amend prove order ensur effect taxat save incom remov undesir distort competit direct respect fundament right principl recognis charter fundament right european union adopt direct chapter introductori provis articl aim ultim aim direct enabl save incom form interest payment made member state benefici owner individu resid tax purpos member state made subject effect taxat accord law member state member state measur ensur task implement direct carri pai agent establish territori irrespect place establish debtor debt claim produc interest articl definit benefici owner purpos direct quot benefici owner quot mean individu receiv interest payment individu interest payment secur evid receiv secur benefit act pai agent mean articl act behalf legal person entiti tax profit gener arrang busi taxat ucit authoris accord direct eec entiti refer articl direct mention case disclos address entiti econom oper make interest payment commun inform compet author member state establish act behalf individu benefici owner disclos pai agent ident benefici owner accord articl pai agent inform suggest individu receiv interest payment interest payment secur benefici owner paragraph appli individu reason step establish ident benefici owner accord articl pai agent unabl identifi benefici owner treat individu question benefici owner articl ident resid benefici owner member state territori adopt ensur applic procedur pai agent identifi benefici owner resid purpos articl procedur compli minimum standard establish paragraph pai agent establish ident benefici owner basi minimum standard vari relat pai agent recipi interest enter contractu relat enter januari pai agent establish ident benefici owner consist address inform dispos pursuant regul forc state establish council direct eec june prevent financi system purpos monei launder contractu relat enter transact carri absenc contractu relat januari pai agent establish ident benefici owner consist address tax identif number alloc member state resid tax purpos detail establish basi passport offici ident card present benefici owner passport offici ident card address establish basi documentari proof ident present benefici owner tax identif number mention passport offici ident card documentari proof ident includ possibl certif resid tax purpos present benefici owner ident supplement refer date place birth establish basi passport offici identif card pai agent establish resid benefici owner basi minimum standard vari relat pai agent recipi interest enter subject condit set resid consid situat countri benefici owner perman address contractu relat enter januari pai agent establish resid benefici owner inform dispos pursuant regul forc state establish direct eec contractu relat enter transact carri absenc contractu relat januari pai agent establish resid benefici owner basi address mention passport offici ident card basi documentari proof ident present benefici owner procedur individu present passport offici ident card issu member state declar resid countri resid establish mean tax resid certif issu compet author countri individu claim resid fail present certif member state issu passport offici ident document consid countri resid articl definit pai agent purpos direct quot pai agent quot mean econom oper pai interest secur payment interest benefit benefici owner oper debtor debt claim produc interest oper charg debtor benefici owner pai interest secur payment interest entiti establish member state interest paid interest secur benefit benefici owner consid pai agent payment secur payment provis appli econom oper reason basi offici evid produc entiti legal person except legal person refer paragraph profit tax gener arrang busi taxat ucit recognis accord direct eec econom oper pai interest secur interest entiti establish member state consid pai agent paragraph commun address entiti total amount interest paid secur entiti compet author member state establish pass inform compet author member state entiti establish entiti refer paragraph option treat purpos direct ucit refer exercis option requir certif issu member state entiti establish present econom oper entiti member state lai detail rule option entiti establish territori econom oper entiti refer paragraph establish member state member state measur ensur entiti compli provis direct act pai agent legal person exempt paragraph finland avoin yhtiö ay kommandiittiyhtiö ky öppet bolag kommanditbolag sweden handelsbolag hb kommanditbolag kb articl definit compet author purpos direct quot compet author quot mean member state author notifi member state commiss countri compet author purpos bilater multilater tax convent fail author compet issu certif resid tax purpos articl definit interest payment purpos direct quot interest payment quot mean interest paid credit account relat debt claim kind secur mortgag carri particip debtor profit incom govern secur incom bond debentur includ premium prize attach secur bond debentur penalti charg late payment regard interest payment interest accru capitalis sale refund redempt debt claim refer incom deriv interest payment directli entiti refer articl distribut ucit authoris accord direct eec ii entiti qualifi option articl iii undertak collect invest establish territori refer articl incom realis sale refund redempt share unit undertak entiti invest directli indirectli undertak collect invest entiti refer asset debt claim refer ucit authoris accord direct eec ii entiti qualifi option articl iii undertak collect invest establish territori refer articl member state option includ incom mention definit interest extent incom correspond gain directli indirectli deriv interest payment mean paragraph pai agent inform proport incom deriv interest payment total amount incom consid interest payment paragraph pai agent inform percentag asset invest debt claim share unit defin paragraph percentag consid determin amount incom realis benefici owner incom deem correspond proce sale refund redempt share unit interest defin paragraph paid credit account held entiti refer articl entiti qualifi option articl consid interest payment entiti paragraph member state option requir pai agent territori annualis interest period time exce year treat annualis interest interest payment sale redempt refund occur period derog paragraph member state option exclud definit interest payment incom refer provis undertak entiti establish territori invest debt claim refer paragraph entiti exceed asset likewis derog paragraph member state option exclud definit interest payment paragraph interest paid credit account entiti refer articl qualifi option articl establish territori invest entiti debt claim refer paragraph exceed asset exercis option member state bind member state percentag refer paragraph paragraph januari percentag refer paragraph paragraph determin refer invest polici laid fund rule instrument incorpor undertak entiti concern fail refer actual composit asset undertak entiti concern articl territori scope direct appli interest paid pai agent establish territori treati appli virtu articl thereof chapter ii exchang inform articl inform report pai agent benefici owner resid member state pai agent establish minimum amount inform report pai agent compet author member state establish consist ident resid benefici owner establish accord articl address pai agent account number benefici owner identif debt claim give rise interest inform interest payment accord paragraph minimum amount inform interest payment report pai agent distinguish categori interest case interest payment mean articl amount interest paid credit case interest payment mean articl amount interest incom refer paragraph full amount proce sale redempt refund case interest payment mean articl amount incom refer paragraph full amount distribut case interest payment mean articl amount interest attribut member entiti refer articl meet condit articl member state exercis option articl amount annualis interest member state restrict minimum amount inform interest payment report pai agent total amount interest incom total amount proce sale redempt refund articl automat exchang inform compet author member state pai agent commun inform refer articl compet author member state resid benefici owner commun inform automat place year month end tax year member state pai agent interest payment made year provis direct eec appli exchang inform direct provid provis direct derog therefrom articl direct eec appli inform provid pursuant chapter chapter iii transit provis articl transit period transit period start date refer articl subject articl belgium luxembourg austria requir appli provis chapter ii receiv inform member state accord chapter ii transit period aim direct ensur minimum effect taxat save form interest payment made member state benefici owner individu resid tax purpos member state transit period end end full fiscal year date date entri forc agreement european commun unanim decis council swiss confeder princip liechtenstein republ san marino princip monaco princip andorra provid exchang inform request defin oecd model agreement exchang inform tax matter releas april hereinaft quot oecd model agreement quot respect interest payment defin direct made pai agent establish respect territori benefici owner resid territori direct appli addit simultan applic countri withhold tax payment rate defin period refer articl date council agre unanim unit state america commit exchang inform request defin oecd model agreement respect interest payment defin direct made pai agent establish territori benefici owner resid territori direct appli end transit period belgium luxembourg austria requir appli provis chapter ii ceas appli withhold tax revenu share provid articl transit period belgium luxembourg austria elect appli provis chapter ii longer appli withhold tax revenu share provid articl articl withhold tax transit period refer articl benefici owner resid member state pai agent establish belgium luxembourg austria levi withhold tax rate year transit period subsequ year pai agent levi withhold tax case interest payment mean articl amount interest paid credit case interest payment mean articl amount interest incom refer paragraph levi equival effect born recipi full amount proce sale redempt refund case interest payment mean articl amount incom refer paragraph case interest payment mean articl amount interest attribut member entiti refer articl meet condit articl member state exercis option articl amount annualis interest purpos point paragraph withhold tax levi pro rata period hold debt claim benefici owner pai agent unabl determin period hold basi inform possess treat benefici owner held debt claim period exist evid date acquisit imposit withhold tax member state pai agent preclud member state resid tax purpos benefici owner tax incom accord nation law subject complianc treati transit period member state levi withhold tax provid econom oper pai interest secur interest entiti refer articl establish member state consid pai agent place entiti levi withhold tax interest entiti formal agre address total amount interest paid secur commun accord subparagraph articl articl revenu share member state levi withhold tax accord articl retain revenu transfer revenu member state resid benefici owner interest member state levi withhold tax accord articl retain revenu transfer member state proportion transfer carri pursuant paragraph articl transfer place latest period month end tax year member state pai agent case paragraph member state econom oper case paragraph member state levi withhold tax measur ensur proper function revenu share system articl except withhold tax procedur member state levi withhold tax accord articl provid procedur order ensur benefici owner request tax withheld procedur benefici owner expressli authoris pai agent report inform accord chapter ii authoris cover interest paid benefici owner pai agent case provis articl appli procedur ensur withhold tax levi benefici owner present pai agent certif drawn compet author member state resid tax purpos accord paragraph request benefici owner compet author member state resid tax purpos issu certif indic address tax identif number fail date place birth benefici owner address pai agent account number benefici owner identif secur certif valid period exceed year issu benefici owner request month request articl elimin doubl taxat member state resid tax purpos benefici owner ensur elimin doubl taxat result imposit withhold tax refer articl accord provis paragraph interest receiv benefici owner subject withhold tax member state pai agent member state resid tax purpos benefici owner grant tax credit equal amount tax withheld accord nation law amount exce amount tax due accord nation law member state resid tax purpos repai excess amount tax withheld benefici owner addit withhold tax refer articl interest receiv benefici owner subject type withhold tax member state resid tax purpos grant tax credit withhold tax accord nation law doubl taxat convent withhold tax credit procedur paragraph appli member state resid tax purpos benefici owner replac tax credit mechan refer paragraph refund withhold tax refer articl articl negoti debt secur transit period refer articl decemb latest domest intern bond negoti debt secur issu march origin issu prospectus approv date compet author mean council direct eec respons author countri consid debt claim mean articl provid issu negoti debt secur made march transit period refer articl continu decemb provis articl continu appli respect negoti debt secur gross earli redempt claus pai agent defin articl establish member state appli withhold tax refer articl pai agent pai interest secur payment interest benefit benefici owner resid member state issu made march aforement negoti debt secur issu govern relat entiti act public author role recognis intern treati defin annex entir issu secur consist origin issu issu consid debt claim mean articl issu made march aforement negoti debt secur issu issuer cover subparagraph issu consid debt claim mean articl articl prevent member state tax incom negoti debt secur refer paragraph accord nation law chapter iv miscellan final provis articl withhold tax direct preclud member state levi type withhold tax refer articl accord nation law doubl taxat convent articl transposit januari member state adopt publish law regul administr provis compli direct forthwith inform commiss thereof member state appli provis januari provid swiss confeder princip liechtenstein republ san marino princip monaco princip andorra appli date measur equival contain direct accord agreement enter european commun unanim decis council ii agreement arrang place provid relev depend territori channel island isl man depend territori caribbean appli date automat exchang inform manner provid chapter ii direct transit period defin articl appli withhold tax term contain articl council decid unanim month januari condit set paragraph met regard date entri forc relev measur countri depend territori concern council decid condit met act unanim propos commiss adopt date purpos paragraph member state adopt provis compli direct refer direct accompani refer occas offici public member state determin refer made member state forthwith inform commiss thereof commun commiss main provis nation law adopt field cover direct correl tabl direct nation provis adopt articl review commiss report council year oper direct basi report commiss propos council amend direct prove order ensur effect taxat save incom remov undesir distort competit articl entri forc direct enter forc dai public offici journal european union articl addresse direct address member state luxembourg june council presid christodoulaki oj oj oj oj direct amend direct ec european parliament council oj oj direct amend act access oj direct amend direct ec european parliament council oj oj direct repeal direct ec european parliament council oj annex list relat entiti refer articl purpos articl entiti consid quot relat entiti act public author role recognis intern treati quot entiti european union gt tabl gt intern entiti european bank reconstruct develop european invest bank asian develop bank african develop bank world bank ibrd imf intern financ corpor inter american develop bank council europ soc dev fund euratom european commun corporación andina de fomento caf andean develop corpor eurofima european coal amp steel commun nordic invest bank caribbean develop bank provis articl prejudic intern oblig member state enter respect abovement intern entiti entiti countri entiti meet criteria entiti consid public entiti nation criteria public entiti market produc administ financ group activ princip provid market good servic intend benefit commun effect control gener govern public entiti larg regular issuer debt state concern guarante public entiti exercis earli redempt event gross claus