18. Januar 2019 Trade tax: foreign passive income attribution Two decisions of the Baden-Württemberg Tax Court have been published in connection with the attribution of foreign passive income for trade tax purposes. In these decisions the Court also raises doubts as to whether the add-back of this type of foreign income is compatible with EU law. Kategorien: Tax CourtSchlagwörter: trade tax, CFC, trade tax deduction, for ...
28. Mai 2018 ECJ decision German CFC regulations to be published on 31 Ma ... The publication of the decision of the European Court for Justice (ECJ) in the Hornbach-Baumarkt case is scheduled for 31 May 2018. Kategorien: European Court of JusticeSchlagwörter: freedom of establishment, CFC, allocatio ...
06. Mai 2015 No foreign passive income attribution for trade tax The Supreme Tax Court has held that the foreign passive income attributed to a domestic parent is to be seen as stemming from a foreign business establishment and is therefore exempt from trade tax. Kategorien: Supreme Tax Court casesSchlagwörter: CFC, passive income, attribution
