Treatment of interest reclassified under thin capitalization rules; Treaties with the Netherlands and US The Czech Supreme Administrative Court gave its decision in Case No. 2Afs 108/2004106 on 10 February 2005 in one of its first decisions in the area of international taxation. (a) Facts. The taxpayer, a company resident in the Czech Republic, received a loan from related party creditors seated in the United States and the Netherlands. The payment of interest on these loans was subject to the profitability of the debtor. Based on the domestic thin capitalization rules, the Czech tax administration considered the interest paid on...