The Resource Leveraged buy-outs and foreign shareholder loans : issues arising from the recent approach of the Italian tax authorities

Leveraged buy-outs and foreign shareholder loans : issues arising from the recent approach of the Italian tax authorities

Label
Leveraged buy-outs and foreign shareholder loans : issues arising from the recent approach of the Italian tax authorities
Title
Leveraged buy-outs and foreign shareholder loans : issues arising from the recent approach of the Italian tax authorities
Creator
Subject
Language
eng
Summary
The Italian tax authorities recently issued an analysis of leveraged buy-out transactions, noting the possibility of recharacterizing shareholder loan agreements as capital contributions by applying paragraph 1.65 of the OECD Transfer Pricing Guidelines, which allows tax authorities to recharacterize structures in accordance with their economic substance. This note questions whether the Italian tax authorities' concept of "economic substance" is compliant with accounting and finance tenets and is still applicable in light of the OECD's base erosion and profit shifting (BEPS) Actions 8-10
Citation source
In: European taxation. - Amsterdam. - Vol. 56 (2016), no. 11 ; p. 527-530
http://library.link/vocab/creatorName
  • Morri, S
  • Guarino, S
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • leveraged buy-out
  • debt capital
  • equity capital
  • economic substance
  • tax authorities
  • BEPS
Label
Leveraged buy-outs and foreign shareholder loans : issues arising from the recent approach of the Italian tax authorities
Instantiates
Publication
Label
Leveraged buy-outs and foreign shareholder loans : issues arising from the recent approach of the Italian tax authorities
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...