27. Dezember 2024 Merger with retroactive tax effect: No offset of profits fro ... According to a recent judgment of the Supreme Tax Court, Section 2 (4) sentence 3 of the Reorganization Tax Act also prevents offsetting positive income generated during the retroactive period by the transferring legal entity with a loss carry-back of the acquiring legal entity from the following (post-merger) year. Kategorien: Supreme Tax Court casesSchlagwörter: loss carry-back, retroactive merger
23. Februar 2021 No tax effect on income of deceased shareholder after retroa ... The Supreme Tax Court held that a merger with retrospective tax effect does not lead to a merger profit for a former and meanwhile deceased shareholder of a limited company even if the shares were acquired gratuitously after the effective (retroactive) tax transfer date. Kategorien: Supreme Tax Court casesSchlagwörter: merger profit, retroactive merger, decea ...
