So-called block acquisitions may meet the terms of Section 8 ...
In a recent judgement, the Supreme Tax Court decided that the participation threshold specified in Section 8b (4) Sentence 6 of the German Corporation Tax Act (“CTA”) (10 % of the share capital) can also be attained through an acquisition transaction which is economically uniform from the acquirer's perspective in a situation where several sellers are involved in the transaction.
Kategorien: Supreme Tax Court cases
Schlagwörter: Intercorporate dividends, tax exemption
