02. September 2015 Full expense deduction for tax group members also for foreig ... The ECJ has held that provisions allowing full expense deduction within tax groups must be applied to otherwise eligible foreign subsidiaries. Kategorien: From EuropeSchlagwörter: tax group, foreign subsidiaries
26. Februar 2015 No refusal of related-party loan write-down for lack of secu ... The Supreme Tax Court has rejected a tax office income adjustment cancelling a write-down of an unsecured loan to a foreign subsidiary as the lack of security was, in the view of the tax office, not at arm’s length. Kategorien: Supreme Tax Court casesSchlagwörter: write-down, unsecured loan, foreign subs ...
26. November 2014 Income adjustment for interest-free loan to foreign subsidia ... The Supreme Tax Court has held that an income adjustment for the interest lost on an interest-free loan to a foreign subsidiary can be made under the Foreign Tax Act unless the loan was granted as a substitute for share capital. Kategorien: Supreme Tax Court casesSchlagwörter: income adjustment, interest-free loan, f ...
