000			02015nab a2200277 c 4500
999			_c149592 _d149592
003			ES-MaIEF
005			20240605185442.0
007			ta
008			240605t2023 ne |||||o|||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100			_960030 _aMonsenego, Jérôme
245		0	_aTargeted measures against intra-group debt financing _helectrónico _bwhat needs and design options in light of the ATAD, transfer pricing rules, and Pillar 2? _c Jérôme Monsenego
500			_aResumen.
520			_aThis article explores the need for interest limitation rules targeting intra-group debt financing, together with certain design options. It is concluded that most issues related to intra-group debt financing are already covered by the anti-tax avoidance directive (ATAD), transfer pricing rules and the Pillar 2 reform. Only the debt/equity balance is not addressed by these rules. Therefore, thin capitalization rules appear to be the most motivated type of targeted rule, if such rules are to be adopted. Other types of targeted rules, such as those taking into account the level of taxation of the recipient or the intention to avoid tax are hardly justified in cases covered by the Pillar 2 reform. In addition, thin capitalization rules can be designed in a manner that does not distinguish between domestic and cross-border situations, hence raising fewer issues of compatibility with the EU fundamental freedoms than other types of targeted rules that rely on the difference in taxation between domestic and cross-border loan transactions.
650		4	_aGRUPOS DE EMPRESAS _932211
650		4	_aGRUPOS DE SOCIEDADES _945118
650		4	_aDEUDORES Y ACREEDORES _956582
650		4	_aINTERES _947502
650		0	_aLIMITACION _970672
650		4	_aSUBCAPITALIZACIÓN _957705
650		4	_aELUSION FISCAL _943410
650		4	_aATAD _967421
650		4	_aUNION EUROPEA _971801
773	0		_9171820 _oOP 2141/2023/10 _tIntertax _w(IEF)55619 _x 0165-2826 _g v. 51, issue 10, October 2023, 15 p.
942			_cRE