Tax & Legal News – Issue 5, September 2015 In this issue: Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC. Date of origin16.09.2015CategoriesTax & Legal NewsKeywordsforeign tax credit, tax group, commodity ...
Arm’s length related-party loan interest to include risk upl ... The Supreme Tax Court has held that a write-off of an irrecoverable related-party loan is not subject to income adjustment under the arm’s length rules, although the interest rate should reflect the bad debt risk. Date of origin09.09.2015CategoriesSupreme Tax Court casesKeywordsbad debt, related-party loan, arm's leng ...