ECJ: Limitation on deduction of interest for an intra-group ...
In a most recent judgment, the European Court of Justice decided that Article 10a of the Dutch Corporate Income Tax Act providing for an interest deduction limitation rule in wholly artificial arrangements is compatible with EU law. Although this article introduces a difference in treatment between a domestic and a cross-border situation, such a difference is justified based on the need to combat tax fraud and tax evasion.
Categories: European Court of Justice
Keywords: interest limitation, interest deduction
