Martin Zetter reviews relevant Danish and Dutch cases, plus interesting guidance issued by the US IRS
With so much talk of BEPS there is a danger of losing touch with what is happening around the world. So this month I am pausing from comments on the digital economy and preventing treaty abuse to look at some country level developments.
I would like to begin with a case from Denmark (Landsskatteretten SKM2014.53.LSR). The Danish subsidiary of the Bombardier group paid a spread of 1.15% on loans it received in a cash pool arrangement to a Swiss affiliate that administered the pool. It received a spread of 0.5% below the overnight reference rate on the funds it deposited. Bombardier Denmark tended to deposit surplus cash rather than borrow from...
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Martin Zetter reviews relevant Danish and Dutch cases, plus interesting guidance issued by the US IRS
With so much talk of BEPS there is a danger of losing touch with what is happening around the world. So this month I am pausing from comments on the digital economy and preventing treaty abuse to look at some country level developments.
I would like to begin with a case from Denmark (Landsskatteretten SKM2014.53.LSR). The Danish subsidiary of the Bombardier group paid a spread of 1.15% on loans it received in a cash pool arrangement to a Swiss affiliate that administered the pool. It received a spread of 0.5% below the overnight reference rate on the funds it deposited. Bombardier Denmark tended to deposit surplus cash rather than borrow from...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: