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Transfer pricing: No deemed interest on royalties not paid due to currency restrictions

International Tax Report

Transfer pricing: No deemed interest on royalties not paid due to currency restrictions

The Danish Eastern High Court has held1 that a Danish parent company was not subject to tax on deemed interest on royalties due but not paid by its Venezuelan subsidiary because of currency restrictions in Venezuela. Arne Møllin Ottosen and Lenni Hangaard Jensen consider this interesting new transfer pricing judgment.

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