16. September 2014 Differing forms of double tax relief not restriction on free ... The ECJ has held that no restriction on the freedom of capital movement arises from relieving domestic double taxation on dividend income under an exact imputation system, whilst foreign double taxation is relieved by exempting the foreign income. Kategorien: From EuropeSchlagwörter: foreign income, double tax relief, divid ...
02. April 2014 Foreign tax credit to reflect personal allowances The Supreme Tax Court has followed an ECJ judgment in basing the maximum foreign tax credit on the total German tax payable on the foreign income as calculated under the assumption that personal allowances and reliefs are first set against the domestic income. The court also held the “per country” limitation to be in accordance with community law. Kategorien: Supreme Tax Court casesSchlagwörter: foreign tax credit, per country limitati ...
