The Resource The interest limitation rule in the Anti-Tax Avoidance Directive (ATAD) and the net taxation principle

The interest limitation rule in the Anti-Tax Avoidance Directive (ATAD) and the net taxation principle

Label
The interest limitation rule in the Anti-Tax Avoidance Directive (ATAD) and the net taxation principle
Title
The interest limitation rule in the Anti-Tax Avoidance Directive (ATAD) and the net taxation principle
Creator
Subject
Language
eng
Summary
This article discusses the rationale for limiting the income tax deduction of interest payments, taking into account the net taxation principle, as well as the compatibility of Article 4 of the Anti-Tax Avoidance Directive (ATAD) with the Treaty on the Functioning of the European Union (TFEU). It also discusses the compatibility of a national provision that is similar to Article 4 of the ATAD, with a national constitution. Assuming that such national interest limitation rule is declared unconstitutional, but, in turn, Article 4 of the ATAD is not declared incompatible with the TFEU, a conflict with EU Law will arise. This is so, because European Union (EU) Law is to be given full effect by EU Member States
Citation source
In: EC tax review. - Alphen aan den Rijn. - Vol. 26 (2017), no. 3 ; p. 112-121
http://library.link/vocab/creatorName
Dourado, A.P
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • interest deduction
  • ATAD
  • constitutional law
  • EU law
Label
The interest limitation rule in the Anti-Tax Avoidance Directive (ATAD) and the net taxation principle
Instantiates
Publication
Label
The interest limitation rule in the Anti-Tax Avoidance Directive (ATAD) and the net taxation principle
Publication

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