Suchergebnisse für: `corp` (369 gefunden)

1. 12. Oktober 2021

   OECD: International tax reform moves forward

   A major reform of the international tax system finalized on 8 October 2021 at the OECD will ensure that Multinational Enterprises (MNEs) will be subject to a minimum 15% tax rate from 2023. The landmark deal will also reallocate more than USD 125 billion of profits from around 100 of the world’s largest and most profitable MNEs to countries worldwide, ensuring that these firms pay a fair share of tax wherever they operate and generate profits.

   Kategorien: From Europe

   Schlagwörter: Pillar One, Pillar Two, international ta ...
2. 05. März 2013

   Corporation tax on portfolio dividends

   The Bundesrat has passed a bill to charge dividend income on investments of less than 10% to corporation tax.

   Kategorien: PwC Reports

   Schlagwörter: portfolio dividend
3. 26. April 2012

   Interest on tax overpayments taxable income of corporations

   The Supreme Tax Court has held that the interest paid to a corporation on an overpayment of corporation tax is taxable income in contrast to the position of income tax payers up to 2010.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: tax interest, tax debt
4. 28. November 2023

   Tax group and corporate reconstructions

   In case of merger of a corporation into a partnership during the year the Supreme Tax Court decided that the acquiring legal entity as the ("new") controlling company also fulfills the requirement of financial integration as a prerequisite for a tax group („Organschaft“) of the former controlling company even if the conversion is not made with retroactive effect from the beginning of the financial year.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: merger, tax group
5. 17. Januar 2011

   Corporation tax imputation credit – round two

   An ECJ advocate general has suggested the court give rather general guidance on the calculation and verification of the creditable corporation tax underlying a dividend from another EU country.

   Kategorien: From Europe

   Schlagwörter: Europäischer Gerichtshof (EuGH), Meilick ...
6. 11. April 2013

   New publication: Tax strategy and corporate reputation

   A new publication has been introduced: PwC's first Tax perspective from its 16th Annual Global CEO Survey - A focus on tax and corporate reputation.

   Kategorien: PwC Reports

   Schlagwörter: Steuern / Tax
7. 02. Dezember 2024

   No tax privileges for fundamentalist and extremist corporati ...

   In two recent decisions published on 28 November 2024, the Supreme Tax Court commented on the tax privileged non-profit status (public-benefit purpose) of extremist corporations and the presumption of conformity resulting from a Federation’s or a Land’s report on the protection of the constitution according to Sections 51 (3) sentence 2 of the German Fiscal Code.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: tax privilege, non-profit associations, ...
8. 25. Juni 2021

   Bundesrat approves the Act to Modernise Corporate Income Tax

   UPDATE: In its session on 25 June 2021, the Bundesrat gave its approval to the Act to Modernise Corporate Income Tax Law. The Bundesrat thus followed the recommendation of the Finance Committee. The law is should enter into force on 1 January 2022.

   Kategorien: Official Pronouncements

   Schlagwörter: Corporation tax, tax group, Exchange rat ...
9. 10. Juni 2015

   Imputation credit for foreign corporation tax refused

   Despite apparently favourable ECJ judgments, the Supreme Tax Court has once again refused a taxpayer credit for the foreign corporation tax due on a dividend received during the currency of the old, imputation tax System.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: imputation, imputation system, Foreign T ...
10. 06. April 2025

    Corporation tax group and non-typical silent partnership

    An untypical silent partnership in the controlled group company does not generally prevent the recognition of a consolidated tax group for corporation tax purposes. With this current decision, the Supreme Tax Court disagrees with the previous opinion of the tax authorities.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: non-typical silent partnership, corporat ...
11. 13. Januar 2017

    Amendment of tax loss utilisation rules for corporations

    Under certain conditions, changes in shareholders and the admission of new investors will in future be possible without giving rise to a forfeiture of losses carried-forward. On 23 December 2016 the Act for the Further Development of Tax Loss Utilisation for Corporations was published after having been adopted by the German Parliament (Bundestag and Bundesrat) on 20 December 2016.

    Kategorien: PwC Reports, Legislation

    Schlagwörter: Corporation tax, curtailment of losses, ...
12. 31. Oktober 2013

    Dividends to US “S corporation” rank for full treaty relief

    The Supreme Tax Court has held that a dividend paid to a US S corporation on a holding of at least 10% is subject to a 5% withholding tax insofar as its shareholders are tax-resident in the USA.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: S corporation, treaty relief
13. 13. September 2012

    Corporate exit tax hinders freedom of establishment

    The ECJ has held the Portuguese taxation of the unrealised gains inherent in a company’s assets on change of corporate residence from Portugal to be an unjustified hindrance on the freedom of establishment.

    Kategorien: From Europe

    Schlagwörter: exit tax, unrealised gains
14. 20. Dezember 2023

    Financing for the Future Act - Significant Changes (also) to ...

    On 14 December 2023, the German Financing for the Future Act (Zukunftsfinanzierungsgesetz, ZuFinG) went into force. The law aims at promoting corporate financing via capital markets and making shares more attractive to the public.

    Kategorien: Tax & Legal News, Legislation

    Schlagwörter: Corporate Governance, Public Companies A ...
15. 16. Oktober 2024

    MoF: Credit of foreign corporate tax under previous imputati ...

    In a most recent circular the Federal Ministry of Finance commented on the method of the foreign corporation tax credit under the formerly applicable German imputation system. The focus of the circular are two judgments of the European Court of Justice as regards the calculation and verification of the creditable corporation tax underlying a dividend from another EU country.

    Kategorien: Official Pronouncements

    Schlagwörter: foreign tax credit, corporate income tax ...
16. 14. Juni 2012

    Foreign corporate shareholder has claim on refund of dividen ...

    The Supreme Tax Court has followed an ECJ case in holding that a foreign corporate shareholder may claim from the local tax office a refund of the tax deducted at source from its dividend.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: Steuern / Tax
17. 26. April 2012

    Foreign corporate shareholder has claim on refund of dividen ...

    The Supreme Tax Court has followed an ECJ case in holding that a foreign corporate shareholder may claim from the local tax office a refund of the tax deducted at source from its dividend.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: withholding tax, refund, dividend
18. 21. März 2013

    Old corporation tax rate on German branch income of non-EU c ...

    The Supreme Tax Court has held that the corporation tax rate on the permanent establishment income of non-EU foreign companies under the old, pre-2001 system was acceptable under community law and the double tax treaty.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: permanent establishment (PE), branch, im ...
19. 17. März 2025

    Hidden profit distributions in the case of stock corporation ...

    The Supreme Tax Court decided that remuneration agreements (for profit related bonuses and sales bonuses) between a stock corporation (AG) and a member of the management board who is also a minority shareholder are generally to be recognized for tax purposes. Only in exceptional cases are they treated as a hidden profit distribution, specifically if there are clear indications in individual cases that the supervisory board of the AG has unilaterally focused on the interests of the management board member in the remuneration agreement.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: hidden distributions
20. 04. März 2021

    Council approves greater corporate transparency for big mult ...

    The EU is taking measures to enhance corporate transparency of big multinational companies. Member states’ ambassadors mandated the Portuguese presidency to engage in negotiations with the European Parliament for the swift adoption of the proposed directive on the disclosure of income tax information by certain undertakings and branches, commonly referred to as the public country-by-country reporting (CBCR) directive.

    Kategorien: From Europe

    Schlagwörter: Country-by-Country Reporting (CbCR) / Er ...
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