20. Dezember 2022 Tax treatment of incongruent advance distributions A civil law resolution for a selective incongruent advance distribution to only one of two shareholders contravening the articles of association but passed unanimously by the shareholders' meeting is also tax effective. Thus, the “left-out” shareholder does not realize taxable income by way of a hidden distribution. Kategorien: Supreme Tax Court casesSchlagwörter: hidden distributions, incongruent advanc ...
24. Februar 2016 Bonus dividend points for co-operative bank members are hidd ... The Supreme Tax Court has held the cost of bonus dividend points of members of a co-operative bank to be a hidden distribution when the programme is open to members only and the maximum bonus is capped. Kategorien: Supreme Tax Court casesSchlagwörter: hidden distributions, co-operative
26. März 2014 Pension promises to owner/managers of companies The Supreme Tax Court has handed down four judgments on pension promises to managing directors who are also majority shareholders specifying rules for distinguishing allowable business expenses from disallowable “hidden distributions”. Kategorien: Supreme Tax Court casesSchlagwörter: owner/manager, pension promises, hidden ...
02. Oktober 2013 Hidden distribution from foreign company is investment incom ... The Supreme Tax Court has held that a benefit from a foreign company to a German shareholder is a hidden distribution taxable in Germany as investment income. Kategorien: Supreme Tax Court casesSchlagwörter: investment income, hidden distributions
05. Januar 2011 Swiss double tax treaty excludes thin capital rule The Supreme Tax Court has held that the thin capital rules in force up to 2007 are in breach of the non-discrimination clause in the Swiss double tax treaty. Kategorien: Supreme Tax Court casesSchlagwörter: Non-discrimination, thin capital rules, ...
05. Januar 2011 Withholding tax on investment income The finance ministry has issued a decree on a number of technical points in connection with the obligation of banks to withhold tax from the investment income of private individuals. Kategorien: Official PronouncementsSchlagwörter: withholding tax, investment income, full ...