Day: May 8, 2019

Eurofast on 7^th May published an article about recent decisions in 6 cases which deal with the interpretation of the Parent-Subsidiary Directive (PSD) and the Interest & Royalties Directive (IRD).  They involved Danish companies, all owned by a parent company resident in another EU Member State, with dividends and interest were distributed to the EU parent, but with the direct ownership of the companies being companies resident in third countries.  The question for the CJEU was whether dividend and interest payments should be exempt from withholding tax when effectively passed on to a company in a third country.  The CJEU stated that a group of companies may be regarded as being an artificial arrangement when its principal objective or one of its principal objectives is to obtain a tax advantage running counter to the aim or purpose of applicable tax law.

https://eurofast.eu/danish-cases-cjeu-issues-important-verdict-on-beneficial-ownership/

Want to know more about nuclear non-proliferation, with a special focus on Iran, North Korea, and trafficking in nuclear commodities, and all about gas centrifuges (central to nuclear weapons development controls)?  In May 2018, the Institute for Science and International Security produced a series of 13 online lectures, available on You Tube, on the subject(s).  The course lectures provide an introduction to the key facets of developing the wherewithal to make nuclear weapons, including uranium enrichment, plutonium production and separation, and nuclear weaponisation.

http://isis-online.org/conferences/detail/nuclear-non-proliferation-technical-primer/