29. November 2017 Immediate taxation on transfer of a foreign branch is not pr ... In a decision published on 23 November 2017 the European Court of Justice (“ECJ”) again considered the question on the taxation of the transfer of assets of a foreign branch in exchange for new shares. The question was referred to it by the Administrative Court of Helsinki in Finland. The ECJ held that the taxpayer must be given the choice between an immediate charge to tax and a deferred payment of tax. Kategorien: From Europe, European Court of JusticeSchlagwörter: Capital gains taxation, EU Law, Foreign ...
09. Juli 2014 No deduction for preparatory costs of failed foreign PE The Supreme Tax Court has held that a taxpayer cannot deduct costs incurred in preparing for a foreign permanent establishment even if, in the event, the establishment never came into existence. Kategorien: Supreme Tax Court casesSchlagwörter: branch, preparatory costs, Foreign Perma ...
