Spain - Case on Intra-Group Debt and Abuse of Law
- F. Carreño; P. Irazusta
- International Transfer Pricing Journal, 2014 (Volume 21), No 4
- 24 July 2014
The authors consider a High Court decision on the deductibility of intra-group interest expense, specifically on the application of fraus legis and other anti-avoidance concepts so as to limit such deductibility.