The Resource Reclassification of interest into dividends in the light of thin capitalisation regulations

Reclassification of interest into dividends in the light of thin capitalisation regulations

Label
Reclassification of interest into dividends in the light of thin capitalisation regulations
Title
Reclassification of interest into dividends in the light of thin capitalisation regulations
Creator
Subject
Language
eng
Summary
This paper first focuses on the practical problem of how thin capitalisation is defined and shows how the relevant equity- and loan-capital can be calculated. It then evaluates the re-characterisation of interest into dividends based on thin capitalisation rules in the light of tax treaties, followed by an evaluation dealing with the problem which arises when the source state decides to reclassify interest into dividends while the resident state of the payment-receiving shareholder does not
Citation source
Bound in: Source versus residence in international tax law. - Wien : Linde, 2005 ; p. 155-181
http://library.link/vocab/creatorName
Weiss, R
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • interest
  • dividend
  • thin capitalization
  • tax treaty
  • source principle of taxation
  • residence principle of taxation
Label
Reclassification of interest into dividends in the light of thin capitalisation regulations
Instantiates
Publication
Label
Reclassification of interest into dividends in the light of thin capitalisation regulations
Publication

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