Fixed Ratio Thin Capitalization Rules in Conflict with the Arm’s Length Principle and Relative Issues of Deductibility

Journal
Asimakopoulos, K.
International
International Transfer Pricing Journal 2012 (Volume 19), No. 6
FormatPDF
EUR
40
| USD
45
(VAT excl.)

Taxation differences and corporate behaviour result in source countries protecting their tax revenue by limiting the tax deductibility of interest under thin capitalization rules or general anti-avoidance rules, in addition to applying the standard transfer pricing rules. The author considers the relationship between certain approaches to thin capitalization rules and the arm’s length principle.