I BankCo, a subsidiary from HoldCo (tax resident in EU Member State A) is tax resident...
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I BankCo, a subsidiary from HoldCo (tax resident in EU Member State A) is tax resident in EU Member State B where the corporate income tax rate amounts to 15%. In 2020 BankCO grants HoldCo a loan for the amount of EUR 100.000 (interest rate 2,5%). According to State's B domestic tax legislation interests paid to a non-resident taxpayer are subject to a 25% withholding tax. Member State A and Member State B have concluded a double tax treaty following the OECD Model Tax Convention. In this treaty Member State B has committed to relieve any outstanding double taxation by using the credit method. Please calculate the tax due in EU Member State A and EU Member State B and explain your conclusion. I BankCo, a subsidiary from HoldCo (tax resident in EU Member State A) is tax resident in EU Member State B where the corporate income tax rate amounts to 15%. In 2020 BankCO grants HoldCo a loan for the amount of EUR 100.000 (interest rate 2,5%). According to State's B domestic tax legislation interests paid to a non-resident taxpayer are subject to a 25% withholding tax. Member State A and Member State B have concluded a double tax treaty following the OECD Model Tax Convention. In this treaty Member State B has committed to relieve any outstanding double taxation by using the credit method. Please calculate the tax due in EU Member State A and EU Member State B and explain your conclusion.
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Tax Treaties When a single entity operates in different countries they need t... View the full answer
Related Book For
Income Tax Fundamentals 2013
ISBN: 9781285586618
31st Edition
Authors: Gerald E. Whittenburg, Martha Altus Buller, Steven L Gill
Posted Date:
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