Business Services Industry
"Thin Cap GLO" decision raises UK-UK questions.
Australasian Business Intelligence, May, 2007
May 07, 2007 (Tax Planning International Transfer Pricing - ABIX via COMTEX) -- On 13 March 2007, the European Court of Justice issued a decision on what is known as the "Thin Cap GLO". The cause concerned disputes about cross-border finance. The Court mostly adhered to the opinion given by the Advocate-General. KPMG contends that the ruling provides means to combat tax abuse while taking a sensible, commercial stance. The court held that debt-financing arrangements featuring parent companies and their offshoots and held on commercial terms on an arm's length basis should be permissible to British tax authorities. The finding raises queries about whether UK-to-UK transfer pricing rules are required.
Publication Date: March 2007
EUROPEAN COURT OF...
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