TY - JOUR
TI - Tax Sparing Credit Clauses and Advance Pricing Agreements as Important Instruments for Tax Optimization
AU - Gajewski, Dominik
TI - Tax Sparing Credit Clauses and Advance Pricing Agreements as Important Instruments for Tax Optimization
AB - The article is devoted to instruments used by international holding companies in their tax optimization strategies. Some of the most commonly adopted instruments include: tax sparing credit clauses and advance pricing agreements. They are particularly frequently used by related entities operating on the territory of the European Union. The article presents an analysis of these constructions with particular indication of tax effects that have a significant influence on reduction of tax liabilities of related entities operating in various residences for tax purposes. The author demonstrates how these instruments can be adopted in various ways, which are often extremely different from the legislator's intention. 
VL - 2018
IS - Issue 12 (4)/ 2018
PY - 2018
C1 - 2299-6834
SP - 18
EP - 27
DO - 10.4467/22996834FLR.18.018.9999
UR - https://ejournals.eu/en/journal/financial-law-review/article/tax-sparing-credit-clauses-and-advance-pricing-agreements-as-important-instruments-for-tax-optimization
KW - tax sparing credit clauses
KW - advance pricing agreements
KW - holding
KW - optimalization