# Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing Directive 77/799/EEC, Division 1: An arrangement that involves deductible cross-border payments made between two or more associated enterprises where at least one of the following conditions occurs:

Extent: E+W+S+N.I.

(a) the recipient is not resident for tax purposes in any tax jurisdiction;
(b) although the recipient is resident for tax purposes in a jurisdiction, that jurisdiction either:
(i) does not impose any corporate tax or imposes corporate tax at the rate of zero or almost zero; or
(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;
(c) the payment benefits from a full exemption from tax in the jurisdiction where the recipient is resident for tax purposes;
(d) the payment benefits from a preferential tax regime in the jurisdiction where the recipient is resident for tax purposes;

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Source: https://www.legislation.gov.uk/eudr/2011/16/annex/IV/part/II/division/C/division/1 (the official version)
Page: https://openlegislation.uk/eu-directive-2011-16/annex-IV/part-II/division-C/division-1
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.