OrbitaxDutch Court Holds Corresponding Adjustment Provisions of Tax Treaty with Russia Not Applicable in Respect of Russian Thin Capitalization Rules
|Treaty Development|Netherlands-Russia
A 5 June 2019 decision of the Court of North Holland has been published regarding the treatment of interest income subjected to Russia's thin capitalization rules.
The case involved a Dutch company that had provided loans amounting to approximately EUR 9 million to its Russian affiliate during 2007 and 2008. When the loans were repaid, the Russian tax authorities applied the thin capitalizat…
Continue Reading
