22. November 2022 Accrual of foreign source income and foreign tax credit Part of the fee payable by the foreign client which is initially retained in anticipation of a potential foreign withholding tax liability of the German self-employed contractor is not immediately subject to income tax in the hands of the latter. According to a ruling of the Supreme Tax Court, the fee withheld is only subject to German income tax if the foreign customer settles the foreign (withholding)tax liability incurred on the total amount of the agreed fees. Kategorien: Supreme Tax Court casesSchlagwörter: foreign tax credit, accruall, foreign wi ...
28. März 2013 Taxable income must take all subsequent events into account The Supreme Tax Court has held that the tax office must adjust taxable income in the light of objective evidence not available when the balance sheet was drawn up. Kategorien: Supreme Tax Court casesSchlagwörter: subsequent event, expense deferral, accr ...