10. November 2021 Supreme Tax Court: Further landmark ruling on intra-group fi ... The Supreme Tax Court issued a further landmark ruling in the area of intra-group financing by which the court strengthens the consideration of risk premiums for subordinated and unsecured loans. Kategorien: Supreme Tax Court cases, Transfer pricin ...Schlagwörter: unsecured loan, intra-group financing, s ...
26. Februar 2015 No refusal of related-party loan write-down for lack of secu ... The Supreme Tax Court has rejected a tax office income adjustment cancelling a write-down of an unsecured loan to a foreign subsidiary as the lack of security was, in the view of the tax office, not at arm’s length. Kategorien: Supreme Tax Court casesSchlagwörter: write-down, unsecured loan, foreign subs ...
