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- Title
Ermittlung fremdüblicher Zinsen auf Konzerndarlehen.
- Abstract
The article deals with the topic of calculating appropriate interest rates for corporate loans. It is pointed out that before applying the cost-plus method, it should be checked whether comparable values can be determined using the price comparison method. The Federal Fiscal Court (BFH) has decided that when assessing the creditworthiness of a corporation, the average creditworthiness of the entire group is not relevant, but rather the creditworthiness of each individual group company. In the present case, the plaintiff was a GmbH whose sole shareholder was a Dutch industrial holding company. The tax office concluded that the agreed interest rates were excessive and should partly be treated as hidden profit distributions. The plaintiff disagreed and successfully filed a revision with the BFH.
- Subjects
BORROWING capacity; INTEREST rates; PRICE fixing; COMMERCIAL loans; LOANS; COMMERCIAL credit; PRICES; CORPORATE ratings; SMALL business loans
- Publication
FinanzRundschau, 2022, Vol 104, Issue 20, p955
- ISSN
2567-4765
- Publication type
Article
- DOI
10.9785/fr-2022-1042011