11. Juni 2015 5% non-deductible deemed expense for foreign dividends can i ... An ECJ advocate general has suggested the court hold that the 5% effectively connected expense add-back for foreign dividends infringes a company’s freedom of establishment if an otherwise comparable domestic company could avoid the add-back by joining a tax group. Kategorien: From EuropeSchlagwörter: foreign dividend, tax group, directly co ...
18. März 2015 No trade tax disallowance of expenses of earning tax-free di ... The Supreme Tax Court has held that there is ultimately no trade tax disallowance of expenses directly connected with tax-free dividend income earned through an Organschaft subsidiary. Kategorien: Supreme Tax Court casesSchlagwörter: trade tax disallowance, tax-free dividen ...
