INTM367030 - EU Directive: Interest & Royalties paid between Associated Companies - claims and applications by non- residents
Business concerns that qualify to claim exemption
The link below provides a list of companies covered by Article 3(a) of the Directive (see Annex to Directive):
A company is an “associated company” if it meets the minimum shareholding requirements of Finance Act 2004/S98(4) and S99(4) that is 25% or more of the capital or voting rights.