Tax Treatment of Interest for Corporations
The book analyses the complex issue of the tax treatment of interest for corporations from different perspectives, including economics, tax policy, comparative law, and EU and international law.
Why this book?
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.
Tax Treatment of Interest for Corporations
DOI: https://doi.org/10.59403/3e2y0kq
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Chapter 1: Introduction
DOI: https://doi.org/10.59403/3e2y0kq001
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Chapter 2: The Debt/Equity Distinction in Corporate Taxation: Does It Work, Does It Matter?
DOI: https://doi.org/10.59403/3e2y0kq002
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Chapter 3: The Debt-Equity Conundrum – A Prequel
DOI: https://doi.org/10.59403/3e2y0kq003
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Chapter 4: Interest Costs Allocation: A Business View
DOI: https://doi.org/10.59403/3e2y0kq004
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Chapter 5: Notional Interest Deduction
DOI: https://doi.org/10.59403/3e2y0kq005
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Chapter 6: The Concept of Interest in Tax Treaties
DOI: https://doi.org/10.59403/3e2y0kq006
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Chapter 7: Thin Capitalization in Brazil
DOI: https://doi.org/10.59403/3e2y0kq007
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Chapter 8: Earnings Stripping
DOI: https://doi.org/10.59403/3e2y0kq008
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Chapter 9: Regime on Danish Interest Deductions
DOI: https://doi.org/10.59403/3e2y0kq009
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Chapter 10: The Case for Withholding Tax on a Net Basis within the EU
DOI: https://doi.org/10.59403/3e2y0kq010
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Chapter 11: Corporate Tax Treatment of Interest: EU State Aid and the EU Code of Conduct Combating Harmful Tax Competition
DOI: https://doi.org/10.59403/3e2y0kq011
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Chapter 12: Thin Capitalization Rules: The ECJ Approach
DOI: https://doi.org/10.59403/3e2y0kq012
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Chapter 13: Tax Treatment of Interest for Corporations
DOI: https://doi.org/10.59403/3e2y0kq013
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Nikolaj Bjørnholm, Peter Blessing, Stephan Eilers, Eric Ginter, Thomas Hermie, Robert van der Jagt, Vinod Kalloe, Theo Keijzer, Marieke Koerts, Otto Marres, Roel Monteiro, Bernard Peeters, Hans Pijl, Paulo Roberto Coimbra Silva, Henk Vording.
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