The Tax Treatment of Bad Debt Risk in Respect of Intra-group Loans: The Score So Far

This contribution deals with recent developments in Dutch case law regarding the tax treatment of bad debt risk, in particular the deductibility of write-downs, in respect of intra-group loans. In addition, the authors express their thoughts on how interest could be calculated on such loans and how the case law dealing with such loans could affect intra-group guarantees.