Lukosz, Krzysztof
Deductibility of credit losses under intercompany gurantees and cash pool arrangements / Krzysztof Lukosz, Sophie Slagter and Etan Wijnberg .-- , 2019
Disponible únicamente en formato electrónico.
Resumen.
Recent Supreme Court's judgments provide a bandwidth for the application of the umbrella credit judgment and shed light on the tax deductibility of credit losses under both cross-guarantees and traditional forms of financial guarantees. The transfer pricing implications for cross-guarantees are far reaching, as every cross-guarantee under arrangements (including cash pooling) that meets the conditions of the umbrella credit judgment, regardless of its specific merits, seems to be taking place in the shareholders sphere.
PRECIOS DE TRANSFERENCIA
CREDITO
PERDIDAS
DEDUCCIONES
PAISES BAJOS
Slagter, Sophie
Wijnberg, Etan
International Transfer Pricing Journal 1385-3074 v. 26, n. 5, September / October 2019, p. 365-370
Deductibility of credit losses under intercompany gurantees and cash pool arrangements / Krzysztof Lukosz, Sophie Slagter and Etan Wijnberg .-- , 2019
Disponible únicamente en formato electrónico.
Resumen.
Recent Supreme Court's judgments provide a bandwidth for the application of the umbrella credit judgment and shed light on the tax deductibility of credit losses under both cross-guarantees and traditional forms of financial guarantees. The transfer pricing implications for cross-guarantees are far reaching, as every cross-guarantee under arrangements (including cash pooling) that meets the conditions of the umbrella credit judgment, regardless of its specific merits, seems to be taking place in the shareholders sphere.
PRECIOS DE TRANSFERENCIA
CREDITO
PERDIDAS
DEDUCCIONES
PAISES BAJOS
Slagter, Sophie
Wijnberg, Etan
International Transfer Pricing Journal 1385-3074 v. 26, n. 5, September / October 2019, p. 365-370