08. Februar 2019 European Court of Justice: Deductible input VAT of a branch ... In its judgment in Morgan Stanley (C-165/17) on 24 January 2019, the ECJ ruled on the ratio of deductible input tax in relation to the internal supplies of a French branch to its head office, a financial service provider in the UK. Kategorien: From EuropeSchlagwörter: Financial Services (FS) / Finanzdienstle ...
01. Januar 2017 Administration publishes regulations on branch profits On December 22, 2016 the finance ministry has finally published its detailed administrative principles on the allocation of profits between a business and its foreign branches. Kategorien: Official PronouncementsSchlagwörter: permanent establishment (PE), branch, AO ...
07. Oktober 2015 Post-dissolution profits and losses from foreign P.E. attrib ... The Supreme Tax Court has held that the profit from the release of a provision no longer required arising from a foreign permanent establishment long after closure falls under the business profits clause of the relevant double tax treaty and is thus taxable in the foreign country. Kategorien: Supreme Tax Court casesSchlagwörter: permanent establishment (PE), branch, pr ...
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 ...
21. März 2013 Old corporation tax rate on German branch income of non-EU c ... The Supreme Tax Court has held that the corporation tax rate on the permanent establishment income of non-EU foreign companies under the old, pre-2001 system was acceptable under community law and the double tax treaty. Kategorien: Supreme Tax Court casesSchlagwörter: permanent establishment (PE), branch, im ...
