The Resource Intra-bank loans : determining a branch's business profits under Article 7 of the OECD Model

Intra-bank loans : determining a branch's business profits under Article 7 of the OECD Model

Label
Intra-bank loans : determining a branch's business profits under Article 7 of the OECD Model
Title
Intra-bank loans : determining a branch's business profits under Article 7 of the OECD Model
Creator
Subject
Language
eng
Summary
Examines the current OECD rules in Art. 7 and the Commentary and in the 1984 Report on the deductibility of interest on intra-bank loans. The article first examines the problem of allocating profits on intra-bank loans to branches in accordance with the arm's length principle. The article then considers three key issues in resolving the main question of whether interest on intra-bank loans is deductible: (a) whether the interest expense on intra-bank loans is recognized for tax purposes, (b) whether an international bank can impose a profit margin on notional intra-bank loans, and (c) how to determine the equity capital of a branch to ensure that interest is not charged on it
Citation source
In: Bulletin for international fiscal documentation. - Amsterdam. - Vol. 59 (2005),
http://library.link/vocab/creatorName
Kobetsky, M
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • interest
  • intra-group services
  • banking
  • attribution of profits
  • arm's length principle
Label
Intra-bank loans : determining a branch's business profits under Article 7 of the OECD Model
Instantiates
Publication
Label
Intra-bank loans : determining a branch's business profits under Article 7 of the OECD Model
Publication

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