{
  "url": "https://openlegislation.uk/eu-directive-2011-16/annex-IV/part-II/division-C/division-1",
  "json_url": "https://openlegislation.uk/eu-directive-2011-16/annex-IV/part-II/division-C/division-1.json",
  "legislation": "eudr/2011/16",
  "legislation_title": "Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing Directive 77/799/EEC",
  "legislation_url": "https://openlegislation.uk/eu-directive-2011-16",
  "path": "annex/IV/part/II/division/C/division/1",
  "kind": "division",
  "number": "1",
  "heading": "An arrangement that involves deductible cross-border payments made between two or more associated enterprises where at least one of the following conditions occurs:",
  "text": "(a) the recipient is not resident for tax purposes in any tax jurisdiction;\n(b) although the recipient is resident for tax purposes in a jurisdiction, that jurisdiction either:\n(i) does not impose any corporate tax or imposes corporate tax at the rate of zero or almost zero; or\n(ii) is included in a list of third-country jurisdictions which have been assessed by Member States collectively or within the framework of the OECD as being non-cooperative;\n(c) the payment benefits from a full exemption from tax in the jurisdiction where the recipient is resident for tax purposes;\n(d) the payment benefits from a preferential tax regime in the jurisdiction where the recipient is resident for tax purposes;",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Inserted by Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements."
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/eudr/2011/16/annex/IV/part/II/division/C/division/1",
    "retrieved_at": "2026-11-01T15:22:03.008049+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}