The Resource Juridical double taxation and economic triple taxation of shareholder loans in Denmark : 'cum in' under Danish tax law

Juridical double taxation and economic triple taxation of shareholder loans in Denmark : 'cum in' under Danish tax law

Label
Juridical double taxation and economic triple taxation of shareholder loans in Denmark : 'cum in' under Danish tax law
Title
Juridical double taxation and economic triple taxation of shareholder loans in Denmark : 'cum in' under Danish tax law
Creator
Subject
Language
eng
Summary
This article, which examines domestic juridical double and economic triple taxation of shareholder loans, concludes that such taxation (i) can result in an effective top marginal tax rate exceeding 100%; (ii) raises issues under, for example, the European Convention on Human Rights (right to property); and (iii) represents, for the individual, a form of 'cum in', i.e. the equivalent of the 'cum ex' that was the basis of a major tax fraud scandal in Europe
Citation source
In: European taxation. - Amsterdam. - Vol. 60 (2020), no. 8 ; p. 370-375
http://library.link/vocab/creatorName
Smith Nielsen, R
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • loan
  • shareholder
  • tax avoidance
  • double taxation
  • European Convention on Human Rights
  • case law
  • ECJ case law
  • ECHR case law
Label
Juridical double taxation and economic triple taxation of shareholder loans in Denmark : 'cum in' under Danish tax law
Instantiates
Publication
Label
Juridical double taxation and economic triple taxation of shareholder loans in Denmark : 'cum in' under Danish tax law
Publication

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