Back To Back Loan Netherlands

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Netherlands - Offshore Manual

Back-to-Back loan schemes have been attacked by the IRS in the past under RevRul 84-152 RevRul 84-153 which purport to look through conduit type loan arrangements involving Netherlands Antilles finance companies and U.S. companies in certain limited cases where the Service believed the tax planning was overly abusive of the U.S. tax rules.

Link: https://www.offshore-manual.com/taxhavens/Netherlands.html

Actived: Saturday Aug 31, 2019 (15 days ago)

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Canadian Back-To-Back Loan Proposals - Tax - Canada

The 2014 federal budget included measures Budget Measures intended to eliminate the use of back-to-back loans to avoid the thin capitalization rules and or withholding tax on interest paid to non-arm s length non-residents so as to protect the Canadian tax base from erosion by limiting the extent

Link: http://www.mondaq.com/canada/x/347422/withholding+tax/Canadian+BacktoBack+Loan+Proposals

Actived: Wednesday Oct 15, 2014 (4 years ago)

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International tax alert - Deloitte US

The existing back-to-back loan rules address loans to or debts owing by a Canadian taxpayer where the creditor is an intermediary and the intermediary is itself indebted to a non-resident or has been provided with certain specified property by a non-resident because it entered into the arrangement with the Canadian taxpayer. If the rules apply the Canadian taxpayer may be

Link: https://www2.deloitte.com/content/dam/Deloitte/ca/Documents/tax/ca-en-ITSL-international-measures-in-2016-%20federal-budget-AODA.PDF

Actived: Sunday Sep 1, 2019 (14 days ago)

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Back-to-back loan - Wikipedia

A Back-to-back loan is a loan agreement between entities in two countries in which the currencies remain separate but the maturity dates remain fixed. The gross interest rates of the loan are separate as well and are set on the basis of the commercial rates in place when the agreement is signed.

Link: https://en.wikipedia.org/wiki/Back-to-back_loan

Actived: Tuesday Sep 10, 2019 (5 days ago)

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The etherlands - PwC

The regime for Dutch finance companies is applicable to back-to-back intercompany loans and intercompany licensing transactions. Under this regime a Dutch finance or licence company must meet the following requirements The company must incur economic risk. The company must have sufficient operational substance. These requirements are further elaborated in two decrees published by the

Link: https://www.pwc.com/gx/en/international-transfer-pricing/assets/netherlands.pdf

Actived: Sunday Sep 1, 2019 (13 days ago)

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Canada Releases Revised Back-to-Back Loan Rules

Canada Releases Revised Back-to-Back Loan Rules by Steve Suarez A notice of ways and means motion NWMM containing legislative changes to the Income Tax Act Canada was tabled in Canada s House of Com-mons on October 20 2014.1 Several international tax measures were included in the NWMM including those that had been released by the Department of Finance on August 29 in draft legislation

Link: http://blg.com/en/News-And-Publications/Documents/Canada_Releases_Revised_Back_to_Back_Loan_Rules_-_October_2014.pdf

Actived: Tuesday Sep 10, 2019 (5 days ago)

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Saying Goodbye To Back To Back Loans And Welcoming

Back to Back Loan BTBL is defined as the arrangement for lending borrowing between related parties. TPS is defined as the document to be provided to the Cyprus Tax Authorities as supporting document evidencing that the transaction took place was based on ALP.

Link: http://www.mondaq.com/cyprus/x/603936/tax+authorities/Saying+Goodbye+To+Back+To+Back+Loans+And+Welcoming+Transfer+Pricing+Regulations

Actived: Wednesday Jun 21, 2017 (2 years ago)

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Mark Coleman Treaty Shopping and Back-to-Back Loan Rules

Mark Coleman Treaty Shopping and Back-to-Back Loan Rules Power Point Presentation for 28 May 2015 IFA Conference in Calgary.

Link: https://taxinterpretations.com/content/350288

Actived: Tuesday Aug 27, 2019 (19 days ago)

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THe Road To Balan Ce creating JoBs - osler.com

THe Road To Balan Ce creating JoBs and OppOrtunities CANADA. Tax Measures Supplementary Information E CO N O M I C A CT IO N P L A N 2014 345 This measure will apply to taxation years of taxpayers that begin after 2014. To ensure that the measure is appropriately targeted stakeholders are invited to submit comments concerning its scope within 60 days after Budget Day. Back-to-Back Loans Both

Link: https://www.osler.com/uploadedFiles/Back-to-Back%20Loans.pdf

Actived: Sunday Sep 8, 2019 (7 days ago)

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