Traduction de «Taux d'impôt applicable aux gains de capital » (Français → Anglais) :

1. Interest or royalty payments arising in a Member State shall be exempt from any taxes imposed on those payments in that Member State, whether by deduction at source or by assessment, provided that the beneficial owner of the interest or royalties is a company of another Member State or a permanent establishment situated in another Member State of a company of a Member State and is effectively subject to tax on the income deriving from those payments in that other Member State at a rate not lower than 70% of the average statutory corporate tax rate applicable in the Member States, without there being the possibility of exemption or a s ...[+++]ubstitution or replacement by payment of another tax.

1. Interest or royalty payments arising in a Member State shall be exempt from any taxes imposed on those payments in that Member State, whether by deduction at source or by assessment, provided that the beneficial owner of the interest or royalties is a company of another Member State or a permanent establishment situated in another Member State of a company of a Member State and is effectively subject to tax on the income deriving from those payments in that other Member State at a rate not lower than 70% of the average statutory corporate tax rate applicable in the Member States, without there being the possibility of exemption or a s ...[+++]ubstitution or replacement by payment of another tax .

(b) tax such profits at a statutory corporate tax rate not lower than 70% of the average statutory corporate tax rate applicable in the Member States while authorising the parent company and the permanent establishment to deduct from the amount of tax due that fraction of the corporation tax related to those profits and paid by the subsidiary and any lower-tier subsidiary, subject to the condition that at each tier a company and its lower-tier subsidiary fall within the definitions laid down in Article 2 and meet the requirements provided for in Article 3, up to the limit of the amount of the corresponding tax due.

(b) tax such profits at a statutory corporate tax rate not lower than 70% of the average statutory corporate tax rate applicable in the Member States while authorising the parent company and the permanent establishment to deduct from the amount of tax due that fraction of the corporation tax related to those profits and paid by the subsidiary and any lower-tier subsidiary, subject to the condition that at each tier a company and its lower-tier subsidiary fall within the definitions laid down in Article 2 and meet the requirements provided for in Article 3, up to the limit of the amount of the corresponding tax due.

If the tax withheld at source has not been refunded within that period, the receiving company or permanent establishment will be entitled on expiry of the year in question to interest on the tax which is refunded at a rate corresponding to the national interest rate to be applied in comparable cases under the domestic law of the source State.

The following measures and reforms in Member States are of particular importance with a view to risk capital activities. Germany has reduced its corporate (in stages until 2005) and income tax rates and will eliminate taxation of sales of shares by corporations as from 2002. France has also reduced its corporate and income tax and increased tax benefits granted to reinvesting business angels. Italy has granted favourable tax treatment to closed-end investment funds. Spain has granted tax incentives to registered venture capital investors.