The A-G has concluded, on various grounds, that the rate for interest on tax due of 8% cannot be maintained and should be reduced. It is now up to the Supreme Court to decide on this matter.
These judgments are very important for the practice, because the Supreme Court addressed the applicationof the anti-abuse provision in holding structures.
At first glance, the possible solutions, which have been developed together with the tax (legal) practice, seem to be a good approach to solve the bottlenecks.
