No deduction of foreign withholding tax in case of abuse
Dividend withholding tax paid by a foreign intermediary company may not be deducted from the taxable income of the local shareholder of a German company if the entire arrangement is abusive and if, therefore, the dividend income is to be allocated to the German shareholder.
Kategorien: Supreme Tax Court cases
Schlagwörter: foreign tax relief, deduction of foreign ...
