No tax requalification of capital: The Dutch Supreme Court

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Abstract

The Dutch Supreme Court ruled on February 7th 2014 that for Corporate Tax purposes capital will be treated as capital and not as a loan although in this case capital had the characteristics of a loan (it had to be repaid after a limited period and the renumeration was a fixed amount of the capital). The author argues that legal certainty did not require the Supreme Court to decide the way it did.
Translated title of the contributionNo tax requalification of capital: The Dutch Supreme Court
Original languageDutch
Article number20140815
Pages (from-to)815-823
Number of pages9
JournalArs Aequi
Volume63
Issue number11
Publication statusPublished - Nov-2014

Keywords

  • Capital, Corporate Tax, Loan

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