Subordinated debt not a liability whilst debtor’s liabilitie ...
The Supreme Tax Court has followed its previous case law in holding that a company financed by subordinated shareholder loans may not take up a liability until the conditions for repayment are met. However, the subordination is a shareholder’s capital contribution to be taken to capital reserve rather than income to the extent the debt had value as an asset at the time.
Kategorien: Supreme Tax Court cases
Schlagwörter: Subordinated debt, capital contribution
