New legislation on tax treatment of hybrid loans

Journal
Molenaars, M.L.; Barten, E.B.
International Transfer Pricing Journal 2002 (Volume 9), No. 3
PriceUSD 45

A description of the history to the implementation of the new hybrid loans tax legislation is given. Technical details of the relevant provisions are discussed, followed by analysis of the effects for the application of the participation exemption and the dividend withholding tax.