Cash Drain Transactions and Tax Deductibility of Certain Expenses

Journal
Chung, Y.L.; Lievens, K.
Belgium
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2011 (Volume 13), No. 2
FormatPDF
EUR
40
| USD
45
(VAT excl.)

The Belgian tax authorities have had increasing success in challenging perceived abusive foreign tax credit schemes. This article considers the current state of those challenges, as well as a recent decision of the Brussels Court of First Instance involving a foreign tax credit scheme and the deductibility of certain expenses and losses.