| Autor: |
Thoemmes, Otmar, Stricof, Robert, Nakhai, Katja |
| Předmět: |
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| Zdroj: |
Intertax, International Tax Review; Mar2004, Vol. 32 Issue 3, p126-137, 12p |
| Abstrakt: |
European Court of Justice (ECJ) decision in the Lankhorst-Hohorst case has revived discussions concerning the compatibility of thin capitalization rules with non-discrimination principles. Traditionally, thin capitalization rules have been used by industrialized countries to prevent corrosion of their tax base by preventing subsidiaries of foreign companies from being financed with excessive levels of debt provided or guaranteed by a foreign parent or other foreign group companies, so that the interest deductions minimize taxable profits in the subsidiary. After ECJ decision, it became clear to all European Union Member States that their thin capitalization regimes would not pass through ECJ. |
| Databáze: |
Complementary Index |
| Externí odkaz: |
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