The Resource Forgiveness of a debt and the territoriality principles

Forgiveness of a debt and the territoriality principles

Label
Forgiveness of a debt and the territoriality principles
Title
Forgiveness of a debt and the territoriality principles
Creator
Subject
Summary
Decision of the Supreme Administrative Court (Conseil d'Etat) nos. 39, 415 and 40, 744 of 15 October 1986. In a recent case, a French company made substantial interest-free loans from 1967 to 1972 to a Dutch holding company of which it was a 50% owner. In 1972 the French company agreed to covert the full amount of the loans into capital of the holding company. The day after the conversion of the loans into shares the French company turned around and sold all its shares in the Dutch holding company at a substantial loss. The French company wanted to deduct the loss as a short-term capital loss because the conversion and subsequent sale occurred over a two-day period. The Supreme Administrative Court agreed with the tax authorities and refused to allow the deduction of the loss
Citation source
In: European taxation. - Amsterdam. - Vol. 27 (1987),
http://library.link/vocab/creatorName
Waardenburg, D.A. van
Geographic coverage
European Union
Language note
English
http://library.link/vocab/subjectName
  • forgiveness of a debt
  • territoriality principle
  • case law
Label
Forgiveness of a debt and the territoriality principles
Instantiates
Publication
Label
Forgiveness of a debt and the territoriality principles
Publication

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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