19. Juli 2016 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 casesSchlagwörter: foreign tax relief, deduction of foreign ...
05. März 2013 Maximum foreign tax credit should not be reduced by domestic ... The ECJ has held that the notional tax on foreign source income should not be reduced by a portion reflecting domestic allowances and reliefs. Kategorien: From EuropeSchlagwörter: foreign tax credit, foreign tax relief, ...