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Vol 22 No 11 Nov/Dec 2017

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The Law of Contract Damages

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Tax Treatment of Interest for Corporations

Edited by: Otto Marres, Dennis Weber

ISBN13: 9789087221621
Published: January 2013
Publisher: IBFD Publications BV
Country of Publication: The Netherlands
Format: Hardback
Price: £123.00

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The tax treatment of interest for corporations continues to engage both tax academics and tax practitioners. In Tax Treatment of Interest for Corporations various aspects of this matter (interest deduction limitations, discriminatory treatment of equity versus debt, preferential tax regimes on group interest income and withholding tax on interest) are dealt with from different perspectives, including economics, tax policy, comparative law, and EU and international law.

Prominent practitioners and academics give their views on the tax treatment of interest.

Subjects discussed are:

  • The debt/equity distinction in corporate taxation from a legal and economic perspective
  • CBIT (comprehensive business income tax) versus ACE (allowance for corporate equity)
  • The concept of interest in tax treaties
  • The notional interest deduction (Belgium)
  • Thin capitalization in Brazil
  • Earnings stripping (Germany)
  • Interest deduction in Denmark
  • Withholding tax on interest within the EU: gross or net?
  • Thin cap rules from an EU perspective
  • EU State aid and the EU Code of Conduct combating harmful tax competition
  • ACTL conference report on tax treatment of interest for corporations
Tax Treatment of Interest for Corporations is a unique combination of academic and practical discussions of economic and policy issues, domestic legislation, EU law and tax treaty law.