The finance ministry has decreed that a company with an untypical silent partner cannot be a member of a corporation tax group.
Tax & Legal
The Supreme Tax Court has held that tax auditors may only evaluate taxpayer data in the taxpayer’s offices or in their own tax offices and must delete it once the assessments for the year in question are final.
The Supreme Tax Court has held that a treaty provision calling for double tax relief for aircrew by foreign tax credit as opposed to the exemption method for other professions does not offend against the equal rights provision of the constitution.
The Supreme Tax Court has followed its previous case law in holding that the provision calling for taxation of treaty-exempt income if the other state does not exercise its right to taxation can only be applied if permitted by the treaty.
The Supreme Tax Court has held that the required documentation in support of a tax-free intra-community supply cannot be substituted by other evidence.
In this issue: PwC Reports, Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC.
The Supreme Tax Court has held that remuneration paid in a single sum for a fourteen-month period can qualify for preferential treatment as remuneration paid for more than one year.
The finance ministry has clarified that its decree of February 4, 2015 on the documentation requirements to be met by resident investors in non-transparent foreign investment funds applies to funds located in other EEA countries only.
The Supreme Tax Court has defined a pre-release marketing subsidy paid by a film owner as a profit-sharing loan in view of the net proceeds-based licence fee payable by the distributor at the end of the fixed-term distributorship.
The finance ministry has decreed that builders may reduce their taxable turnover by the amount of a customer retention that cannot be collected for two to five years, unless they could have satisfied their customer’s need for security with a bank guarantee.