Triangular cases and the Interest and Royalties Directive : untying the Gordian Knot? - part 1

This is the first article in a three-part series, which considers the Interest and Royalties Directive in relation to the problems posed by triangular cases. Part 1 commences by recalling the triangular cases issue in a mere tax treaty setting, considering a number of cases in the process. The three parts, in general, focus on PE triangular cases involving interest and royalties.