The Resource Courts hold that notional interest deduction does not require substance

Courts hold that notional interest deduction does not require substance

Label
Courts hold that notional interest deduction does not require substance
Title
Courts hold that notional interest deduction does not require substance
Creator
Subject
Language
eng
Summary
The Courts of Appeal of Antwerp and Liège are of the opinion that interposing a Belgian finance company is, as such, not abnormal even if the company holds one single loan. The receiving and granting of a loan, and the management thereof, is clearly an economic activity, and ? given the magnitude of the loan ? not of an abnormal nature. The notional interest deduction is not conditional upon a certain level of economic substance
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 23 (2016),
http://library.link/vocab/creatorName
Mortier, F
Geographic coverage
European Union
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • notional interest deduction
  • substance requirements
  • case law
Label
Courts hold that notional interest deduction does not require substance
Instantiates
Publication
Label
Courts hold that notional interest deduction does not require substance
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...