02. Dezember 2024 Taxation of benefits from a Swiss family foundation The Supreme Tax Court decided that the one-time cash payment and distribution of shares to the plaintiff from a Swiss-based foundation in 2017 (year in dispute) was subject to German income tax as income from capital investment pursuant to Section 20 (1) no. 9 of the German Income Tax Act. In its decision the court explained under which circumstances the income from such a benefit is economically comparable to a regular profit distribution. Kategorien: Supreme Tax Court casesSchlagwörter: distribution, foreign foundation
29. Mai 2013 No return of capital contribution in the same year The Supreme Tax Court has held that distributions to shareholders may only rank as a (tax free) return of a capital contribution if they do not exceed the balance brought forward at the beginning of the year. Kategorien: Supreme Tax Court casesSchlagwörter: capital contribution, distribution, retu ...
