ECJ: Refusal to allow the utilization of foreign branch fina ...
Following the request for a preliminary ruling from the German Supreme Tax Court, the European Court of Justice (ECJ) is called to decide whether a German parent company has the right to deduct from its taxable income losses incurred by its UK branch, which had ceased activity and thus could no longer utilize its accumulated tax losses in the UK. In his Opinion, the Advocate General has suggested that the German rules denying the import of losses of foreign branches are not contrary to the EU principles of freedom of establishment.
Kategorien: European Court of Justice
Schlagwörter: foreign branch losses, final losses, hea ...