The Resource Practical implications from four Dutch Supreme Court rulings, U.S. characterization of intercompany debt instruments

Practical implications from four Dutch Supreme Court rulings, U.S. characterization of intercompany debt instruments

Label
Practical implications from four Dutch Supreme Court rulings, U.S. characterization of intercompany debt instruments
Title
Practical implications from four Dutch Supreme Court rulings, U.S. characterization of intercompany debt instruments
Creator
Subject
Language
  • eng
  • eng
Summary
This article examines four recent Dutch cases on intercompany loans. The authors address the current state of Dutch tax law on intragroup loans and the practical implications of these cases, focusing on the Dutch transfer pricing perspective. In this context, the current positions of the Supreme Court of the Netherlands is illustrated, as well as points to be considered by the taxpayer. The article also provides a short overview and comparison of the U.S. practice with respect to the qualification of a financial instrument as debt or equity, for U.S. tax and transfer pricing purposes
Citation source
In: Tax management transfer pricing report. - Arlington. - Vol. 20 (2012),
http://library.link/vocab/creatorName
  • Blough, S.R
  • Sporken, C.J.E.A
  • Middelkoop, B
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • intercompany loan
  • arm's length principle
  • case law
Label
Practical implications from four Dutch Supreme Court rulings, U.S. characterization of intercompany debt instruments
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2012/T/TAXMATRP/vol.20/24_1286-1293.zip
Publication
Note
20120612

Library Locations

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