I am just seeking clarification on the matters below.
Corporation tax: UK company pays copyright royalties to a company in another EU company and then grants another licence to a non-EU country company. The two companies (EU and UK) are under common control by a non-UK resident director. My understanding is that the UK co. does not withold tax at 20% from what it pays the Greek co. because the double tax treaty between Greece and the UK (article VI) states that exempt from tax in the UK and tax treaties prevail over domestic law. In my opinion the anti-avoidance measure March 2016 that nullify the treaty where connected parties doesnt apply because Greece is not a tax heaven country and hence no benefit is secured by these arrangements.
VAT: the supply of royalies to the non-EU company is outisde the scope of UK VAT (general rule B2B). The buyin in of services from the Greek company is under the reverse charge mechanism for the UK company.
many thanks for your help.