![Cécile Brokelind. Photo.](/sites/lusem.lu.se/files/styles/lu_personal_page_desktop/public/2024-04/CcileBrokelind.jpg.webp?itok=NNk1OsqA)
Cécile Brokelind
Professor
![Cécile Brokelind. Photo.](/sites/lusem.lu.se/files/styles/lu_personal_page_desktop/public/2024-04/CcileBrokelind.jpg.webp?itok=NNk1OsqA)
Interest Deduction Limitations in Sweden Post-Lexel: The Relevance of the Free Movement of Capital
Author
Summary, in English
In Lexel (Case C-484/19), the Swedish interest deduction limitation rules were found to be in breach of article 49 of the TFEU on the freedom of establishment, as they presumed abusive practices even in respect of arm’s length-based transactions. The present article puts the case into context and highlights follow-up issues raised before lower Swedish tax courts in the context of loan transactions involving associated companies in third countries. Indeed, recent ECJ case law indicates that transactions between associated companies in the European Union and in third countries are protected under article 63 of the TFEU on the free of movement of capital.
Department/s
- Department of Business Law
Publishing year
2023-06-01
Language
English
Pages
234-246
Publication/Series
European Taxation
Volume
63
Issue
6
Document type
Journal article
Publisher
IBFD
Topic
- Law (excluding Law and Society)
Status
Published
ISBN/ISSN/Other
- ISSN: 0014-3138