Case on Intra-Group Debt and Abuse of Law

Journal
Carreño, F.; Irazusta, P.
Spain
International Transfer Pricing Journal 2014 (Volume 21), No. 4
PriceUSD 45

The authors consider a High Court decision on the deductibility of intra-group interest expense, specifically on the application of fraus legis and other anti-avoidance concepts so as to limit such deductibility.