6 Amendments of Liem HOANG NGOC related to 2010/0387(CNS)
Amendment 4 #
Proposal for a directive
Article 3 – paragraph 1 – point a – point i
Article 3 – paragraph 1 – point a – point i
(i) at least to any company of a Member State which fulfils the conditions set out in Article 2 and hamaintains for an uninterrupted period of at least two years a minimum holding of 105 % in the capital of a company of another Member State fulfilling the same conditions;
Amendment 5 #
Proposal for a directive
Article 3 – paragraph 1 – point a – point ii
Article 3 – paragraph 1 – point a – point ii
(ii) under the same conditions, to a company of a Member State which hamaintains for an uninterrupted period of at least two years a minimum holding of 105 % in the capital of a company of the same Member State, held in whole or in part by a permanent establishment of the former company situated in another Member State.
Amendment 6 #
Proposal for a directive
Article 3 – paragraph 2 – point a
Article 3 – paragraph 2 – point a
(a) replacadding, by means of bilateral agreement, to the criterion of a holding in the capital by, that of a holding of voting rights;
Amendment 7 #
Proposal for a directive
Article 3 – paragraph 2 – point b
Article 3 – paragraph 2 – point b
Amendment 9 #
Proposal for a directive
Article 4 – paragraph 1 – point a
Article 4 – paragraph 1 – point a
(a) refrain from taxing such profits, provided that they have been taxed in the country of the subsidiary at a statutory corporate tax rate not lower than 75% of the average statutory corporate tax rate applicable in the Member States; or
Amendment 11 #
Proposal for a directive
Article 4 – paragraph 1 – point b
Article 4 – paragraph 1 – point b
(b) tax such profits at a statutory corporate tax rate not lower than 75% of the average 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.