EU Court of Justice Greenlights Bulgarian Withholding Tax on Imputed Interest

The Court of Justice of the European Union (CJEU) on 24 February 2022 issued its decision in the Viva Telecom case. The case concerned a Bulgarian company that contracted a convertible interest-free loan from its sole Luxembourg shareholder. The contractual terms provided for the repayment of the principal after 60 years unless the shareholder contributes the loan to the capital of the debtor.…
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