Deductibility of credit losses under intercompany gurantees and cash pool arrangements Krzysztof Lukosz, Sophie Slagter and Etan Wijnberg
By: Lukosz, Krzysztof
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Contributor(s): Slagter, Sophie | Wijnberg, Etan.
Material type: 
ArticlePublisher: 2019Subject(s): PRECIOS DE TRANSFERENCIA | CREDITO | PERDIDAS | DEDUCCIONES | PAISES BAJOS
In:
International Transfer Pricing Journal v. 26, n. 5, September / October 2019, p. 365-370Summary: 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.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2019/5-12 (Browse shelf) | Available | ITPJ/2019/5-12 |
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.
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