Cash Drain Transactions and Tax Deductibility of Certain Expenses

Journal
Chung, Y.L.; Lievens, K.
Belgium
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2011 (Volume 13), No. 2
PriceUSD 45

The Belgian tax authorities have had increasing success in challenging perceived abusive foreign tax credit schemes. This article considers the current state of those challenges, as well as a recent decision of the Brussels Court of First Instance involving a foreign tax credit scheme and the deductibility of certain expenses and losses.