C-553/16‘TTL’ EOOD v Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna praktika’ - Sofia

Domstolens egne nøkkelord

Reference for a preliminary ruling — Freedom to provide services — Corporate taxation — Payments made by a company resident in a Member State to non-resident companies for the leasing of rail tankers — Obligation to charge withholding tax on income from a domestic source paid to a non-resident company — Non-compliance — Double taxation conventions — Charging the resident company default interest for non-payment of the withholding tax — Interest payable from the expiry of the statutory time limit for payment until the date on which evidence that the double taxation convention is applicable is furnished — Irrecoverable interest.

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