Suchergebnisse für: `contributor` (754 gefunden)

1. 17. August 2011

   Contributions under Reconstructions Tax Act 1995 always at r ...

   The Supreme Tax Court has held that the value of a contribution in kind under the Reconstructions Tax Act 1995 as taken up by the recipient is binding on the contributor. Changes in retrospect are binding on both parties.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: contribution in kind, contributor
2. 08. August 2016

   Negative Goodwill in the case of a contribution

   The Federal Supreme Tax Court upheld a decision of the Münster Tax Court and held:

   Kategorien: Supreme Tax Court cases

   Schlagwörter: contribution, Reorganisation Tax Act, Ne ...
3. 26. Juni 2013

   Flood relief measures

   The finance ministry has issued a decree easing the formalities to be followed by those wishing to contribute to the support for the victims of the recent Elbe and Danube flooding.

   Kategorien: From Europe

   Schlagwörter: Sponsoring, flood relief, flooding
4. 08. Januar 2014

   Compulsory employer contributions to Swiss pension fund tax- ...

   The Supreme Tax Court has held that the employer contributions to a legally compulsory pension fund are tax exempt in Germany. Voluntary contributions are a taxable benefit.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Swiss pension fund, employer contributio ...
5. 29. Mai 2013

   No return of capital contribution in the same year

   The Supreme Tax Court has held that distributions to shareholders may only rank as a (tax free) return of a capital contribution if they do not exceed the balance brought forward at the beginning of the year.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: capital contribution, distribution, retu ...
6. 19. Oktober 2016

   Tax neutral repayment of capital contributions by companies ...

   The transfer of shares to German-residents shareholder as part of a US spin-off generally constitutes investment income under Section 20 (1) No. 1 of the Income Tax Act (ITA); Section 20 (1) No. 1 Sentence 3 ITA is to be interpreted in line with EU law, so that companies resident outside the EU may also repay capital contributions on a tax neutral basis, even though they do not maintain a contributions account for tax purposes under Section 27 of the Corporation Tax Act (CTA).

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Steuern / Tax
7. 16. März 2011

   Employer’s pension contribution tax-free regardless of wordi ...

   The Supreme Tax Court has held that an employer’s pension fund contribution paid on behalf of an employee is not taxable merely because it was described as a payment on behalf of the employee.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: pension fund, employer's, contributions
8. 10. August 2011

   Real estate transfer tax on capital contribution of shares t ...

   The Supreme Tax Court has again held that the real estate transfer tax due on a contribution of a shareholding in another company is to be written off as a current operating expense.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: real estate transfer tax, contribution, ...
9. 02. September 2021

   Contributions to US- 401(k) pension plan taxed as income fro ...

   The Regional Tax Court of Rhineland Palatinate has decided that contributions to the US 401(k) retirement plan deducted at source from the employee's salary are to be taxed as income from employment in Germany.

   Kategorien: Tax Court

   Schlagwörter: employment income, pension plan, retirem ...
10. 04. Februar 2014

    Employer contributions to social security schemes in other m ...

    The finance ministry has decreed that employer contributions to the social security systems of other member states of the EU/EEA and of Switzerland shall be a tax-free benefit for German resident employees up to the level of the equivalent German charge.

    Kategorien: Official Pronouncements

    Schlagwörter: social security, employer contributions
11. 29. Juni 2017

    Refusal to deduct French social security contributions not c ...

    The German refusal of a deduction for social security contributions paid by a German resident French government official does not meet the EU-requirement for free movement of workers, since its effective exclusion under German law placed her at a comparative disadvantage vis-à-vis her German colleague.

    Kategorien: From Europe

    Schlagwörter: social security contributions, free move ...
12. 25. Oktober 2021

    Loss utilisation restriction (Section 2a (1) Sentence 1 No. ...

    According to a decision of the Supreme Tax Court published on 21 October 2021, the loss of a silent partner's contribution, which is reflected as a partial write-down for tax purposes, does not fall within the scope of the loss utilisation restriction under Section 2a (1) Sentence 1 No. 5 in conjunction with Sentence 2 Income Tax Act (ITA).

    Kategorien: Tax Court

    Schlagwörter: investment write-down, silent partnershi ...
13. 06. Mai 2015

    No foreign passive income attribution for trade tax

    The Supreme Tax Court has held that the foreign passive income attributed to a domestic parent is to be seen as stemming from a foreign business establishment and is therefore exempt from trade tax.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: CFC, passive income, attribution
14. 03. September 2014

    Pension promise to owner/manager hidden distribution

    The Supreme Tax Court has held the annual cost of a pension promise to a former owner/manager who retired before the pension date to be a hidden distribution.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: owner/manager, pension promise
15. 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 cases

    Schlagwörter: investment income, hidden distribution
16. 18. Januar 2019

    Trade tax: foreign passive income attribution

    Two decisions of the Baden-Württemberg Tax Court have been published in connection with the attribution of foreign passive income for trade tax purposes. In these decisions the Court also raises doubts as to whether the add-back of this type of foreign income is compatible with EU law.

    Kategorien: Tax Court

    Schlagwörter: trade tax, CFC, trade tax deduction, for ...
17. 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 cases

    Schlagwörter: hidden distribution, co-operative
18. 12. März 2019

    ECJ: Passive income attribution from controlled companies re ...

    The European Court of Justice has held that the German provision for the taxation of  controlled company income from invested capital from outside the EU might fall under the “grandfather” clause of Art 64 TFEU, provided the German legislation has remained substantially unchanged since that date. It is now for the Supreme Tax Court to decide finally whether this is the case.

    Kategorien: European Court of Justice

    Schlagwörter: standstill clause, foreign passive incom ...
19. 05. September 2021

    Distributions from Luxembourg investment company (SICAV) exe ...

    Corporations with at least a 25% share in a Société d'investissement à capital variable (SICAV), a Luxembourg investment company, do not have to pay income tax in Germany on the dividends received from the SICAV in 2010. This also applies if the Luxembourg tax authorities – for whatever reason - did not exercise their right of taxation at source and the distributions hence remained untaxed.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: SICAV, intercompany dividend privilege
20. 09. Januar 2011

    Active business can be contracted out

    The Supreme Tax Court has held that a Dublin docks reinsurance company that subcontracted its operation under a management agreement was an active business within the meaning of the Foreign Tax Act.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: Active business, contracted out, CFC pro ...
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