International Tax Handbook - ITHCONT12

international tax handbook: contents

INTEREST. SOME PRACTICAL PROBLEMS

ITH1200+The division of taxing rights
ITH1205+Borrowing for outward investment
ITH1213+The treaty approach
ITH1220Interest: thick capitalisation
ITH1221+Thin capitalisation
ITH1227+Defences against thin capitalisation
ITH1240Interest: exploiting the sharing of taxing rights
ITH1241Interest: Delaware Link
ITH1242+Legislation against the 'Delaware Link'
ITH1248+Other forms of 'double dip'
(The text at this point has been withheld under the Code of Practice on Access to Government Information)
Equity disguised as debt
(The text at this point has been withheld under the Code of Practice on Access to Government Information)
ITH1276Interest: detection of schemes
ITH1280Interest: Outward Loans
ITH1281Interest: Deferred interest loans
ITH1282Interest: FA93 S61-66
ITH1283Interest: FA96





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