Tax & Legal

Ground-breaking new EU rules come into effect from 1 January 2024 introducing a minimum rate of effective taxation of 15% for multinational companies active in EU Member States.

On 19 May 2022, the members of the European Parliament (MEPs) approved a Commission proposal implementing the recent international agreement on a global minimum corporate tax rate of 15%.

The Supreme Tax Court has held that a tax office cannot be required to issue a provisional assessment restricting the immediate deduction of the loss brought forward, merely because of the possibility that the remaining loss to be carried forward might be invalidated by a share transaction abroad at some future point in time.

The Supreme Tax Court has held the “minimum taxation” deferral of loss relief to be constitutionally acceptable.

The finance ministry has instructed tax offices to allow payment suspension requests on assessments to “minimum tax” where the future offset of the loss to be carried forward is excluded by law.