Abstract
When outlining the measure on excessive borrowing from own company, the government indicated that proportionality and deferral and avoidance possibilities will be important factors in the exact design of the measure. Given the outline outlined by the secretary of state, the need for the measure would only arise to the extent that there would be actual deferral or avoidance of taxation.
However, according to the authors, within the current tax frameworks, there is only limited deferral or postponement of taxation due to borrowing from one's own company. Against that background, the necessity and usefulness of the measure is therefore low. However, this is not to say that the measure does not have a major impact.
However, according to the authors, within the current tax frameworks, there is only limited deferral or postponement of taxation due to borrowing from one's own company. Against that background, the necessity and usefulness of the measure is therefore low. However, this is not to say that the measure does not have a major impact.
Translated title of the contribution | Consultation proposal excessive borrowing from own company: Utility and necessity of the measure |
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Original language | Dutch |
Article number | WFR 2019/59 |
Pages (from-to) | 343-347 |
Number of pages | 5 |
Journal | Weekblad Fiscaal Recht |
Volume | 2019 |
Issue number | 7280 |
Publication status | Published - 28 Mar 2019 |
Externally published | Yes |
Keywords
- excessive borrowing
- director major shareholder