External financing is increasingly more difficult to obtain. How does it impact transfer pricing policies?
According to the latest update of the quarterly bank lending survey of the European Central Bank (“ECB”), the loan application rejection rate within the Eurosystem continued to increase during the first quarter of 2024, albeit at a slower rate than the previous quarter. In addition, Euro area banks reported a small further net tightening of
Positive ruling on deductibility of interest costs on loans contracted in order to finance capital reduction in case of an ‘over-capitalised’ company
The Belgian ruling office recently published a positive decision deciding that interest costs related to the intercompany loan are deductible for tax purposes since the costs are borne by the company with the purpose to preserve or generate taxable income. In the case at hand, a factoring company with ‘an excessive amount of equity’ is
