31.03.2022 ECJ: Withholding tax on notional interest in case of interes ... In a Bulgarian case the European Court of Justice (ECJ) held that EU law does not preclude national legislation imposing withholding tax on notional market-based interest (mandated under local tax anti-avoidance rules). Such withholding tax cannot be exempt under the regimes of the IRD (EU Interest - Royalty Directive 2003/49/EC) and the PSD (EU Parent-Subsidiary Directive 2011/96/EU) as there have been no actual payments of interest. Categories: European Court of JusticeKeywords: notional tax, interest-free loan, notion ...
26.11.2014 Income adjustment for interest-free loan to foreign subsidia ... The Supreme Tax Court has held that an income adjustment for the interest lost on an interest-free loan to a foreign subsidiary can be made under the Foreign Tax Act unless the loan was granted as a substitute for share capital. Categories: Supreme Tax Court casesKeywords: income adjustment, interest-free loan, f ...
