Article 104(3), first subparagraph, of the Rules of Procedure – Free movement of capital – Freedom of establishment – Taxation – Corporation tax – Loan agreement between companies – Resident borrowing company – Shareholder lending company established in a non-member country – Meaning of ‘substantial holding’ – Payment of loan interest – Classification – Covert distribution of profits.
Lasertec Gesellschaft fur Stanzformen mbH v Finanzamt Emmendingen
