Quotation Capristano Cardoso, Gabriela. 2019. Treatment of Currency Losses and Interest-Free Loans Under the Dutch Participation Exemption. Transfer Pricing International (TPI). 2019 (4), 217-220.


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Abstract

The case discusses whether the participation in an Irish subsidiary of a Dutch company qualifies as a low-tax participation and thus is excluded from the Dutch participation exemption benefit. In calculating the tax burden of the Irish subsidiary, the Supreme Court of the Netherlands has discussed the impact of foreign currency losses and the reclassification of an interest-free loan as hidden dividend distribution. In this article, Gabriela Capristano Cardoso provides an analysis of the case 17/03918 decided by the Supreme Court of the Netherlands on November 2nd, 2018, and discusses its implications in the international tax environment.

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Publication's profile

Status of publication Published
Affiliation WU
Type of publication Journal article
Journal Transfer Pricing International (TPI)
Language English
Title Treatment of Currency Losses and Interest-Free Loans Under the Dutch Participation Exemption
Volume 2019
Number 4
Year 2019
Page from 217
Page to 220
URL https://swk.media/lion_doc/art-tpi-2019-04-217a/
DOI n.a.
Open Access N

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Capristano Cardoso, Gabriela (Details)
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Austrian and International Tax Law IN (Details)
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