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Subject: The exceeding part of the interest payments fin. According the intercompany loan agreements entered into by XXX and YYY, the agreed annual interest rate is 5%. However, according to the guidance of the Swiss Federal Tax Administration the maximum interest rate on EUR-loans granted by related companies is 3.75% (in 2014) and 1.0% (in 2015). The exceeding part of the interest payments would be deemed a hidden dividend.Как-то не соображу...
Сумма превышения, содержащаяся в выплатах процентов... ?
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