Suchergebnisse für: `corporate-income-tax` (48 gefunden)

  4. 26. Juli 2021

    British university college recognized as charitable foundati ...

    An ancient english university college may meet the requirements of a charitable foundation under German law and be exempt from corporate income tax because of its non-profit status. In its decision the Supreme Tax Court also found that the legal structure of the college is equivalent to that of a German foundation within the meaning of Sec. 80 (1) of the German Civil Code.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: british university college, charitable o ...
  5. 12. November 2021

    Update: EU regulations force more tax transparency on multin ...

    On 11 November the EU Parliament will vote on a provisional agreement with the Council that would oblige companies with an annual revenue of more than €750 million and with operations in more than one country to declare the profits they have made, the corporate income tax paid and the number of employees in each EU country for the previous financial year.

    Kategorien: From Europe
    Schlagwörter: Country-by-Country Reporting (CbCR) / Er ...
  6. 09. Oktober 2024

    ECJ: Limitation on deduction of interest for an intra-group ...

    In a most recent judgment, the European Court of Justice decided that Article 10a of the Dutch Corporate Income Tax Act providing for an interest deduction limitation rule in wholly artificial arrangements is compatible with EU law. Although this article introduces a difference in treatment between a domestic and a cross-border situation, such a difference is justified based on the need to combat tax fraud and tax evasion.

    Kategorien: European Court of Justice
    Schlagwörter: interest limitation, interest deduction
  10. 30. August 2024

    Foreign currency losses in the case of shareholder loans to ...

    In a most recent decision, the Supreme Tax Court held that foreign currency losses on shareholder receivables similar to loans do not reduce the taxable income of the corporation. This was decided by the Supreme Tax Court in its interpretation of Section 8b (3) Corporation Tax Act as valid in 2014 and which deals with investments in other corporations and the non-deductibility of losses in connection with certain shareholder loans.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: Loss relief, shareholder loan
  11. 01. September 2025

    Loss utilization after termination of a two-tier limited par ...

    In a recently published judgment, the Supreme Tax Court decided in a case involving the transfer of a limited partnership to the sole remaining limited partner in the legal form of a limited liability company (GmbH) by way of universal succession through accrual, among other things, that the limited partner's allowable loss determined at the time of termination within the meaning of Section 15a (4) of the Income Tax Act can be offset by the limited limited company against its future profits.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: limited partnership, loss carryforward t ...
  12. 16. Februar 2023

    Tax consolidation group in case of insolvency

    The profit pooling agreement under the concept of a tax consolidation group (Organschaft) must be concluded for at least five years and be followed throughout its entire term. According to the decision of the Supreme Tax Court recognition of the Organschaft is to be denied with retroactive effect if preliminary annual financial statements of the controlled company can no longer be adjusted due to insolvency and if a different result would have been reported in the final annual financial statements if the accounting principles under commercial law had been applied correctly.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: profit pooling agreement, insolvency, ta ...
  13. 01. Februar 2023

    Future expenses not to be included when calculating maximum ...

    When determining the amount of foreign withholding tax credit against German income or corporation tax, expenses for future earnings are not to be included in the calculation, which - in the case of dispute before the Supreme Tax Court- improved the plaintiffs tax credit potential. This decision of the Supreme Tax Court contrasts with the view held by the tax authorities.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: foreign tax credit
  15. 22. März 2022

    Portuguese dividend withholding tax for foreign UCITS in bre ...

    Does the free movement of capital require a Member State to tax non-resident and resident investment vehicles according to the same tax system? This is the question raised in the request for a preliminary ruling submitted to the European Court of Justice (ECJ) by the Portuguese tax court (Tax Arbitration Tribunal). Contrary to the Opinion of the Advocate General the ECJ decided that the withholding tax on dividends paid to non-resident Undertakings for Collective Investments in Transferable Securities (UCITS) is in violation with current EU Law.

    Kategorien: European Court of Justice
    Schlagwörter: UCITS / OGAW, portuguese dividend withho ...
  16. 06. Oktober 2022

    Finance Ministry promises relief for increased energy costs ...

    The Federal Ministry of Finance (MoF), in conjunction with the supreme tax authorities of the Federal States, issued a decree according to which the tax offices are to use the tools available to them under the statutes in the interests of those taxpayers who are significantly affected by the increase in energy costs because of the war of aggression of Russia against Ukraine.

    Kategorien: Official Pronouncements
    Schlagwörter: energy costs
  19. 26. März 2022

    No claim for refund of withholding tax for Canadian pension ...

    The Regional Tax Court of Munich rendered its final decision in the case of the College Pension Plan of British Columbia which is a pension fund in the legal form of a trust under Canadian law. The court held that the pension fund is not entitled to relief from withholding tax on dividends from domestic portfolio holdings. The court saw no violation of the free movement of capital. This judgment was preceded by a decision of the European Court of Justice (ECJ) as a result of a preliminary request submitted by the Munich tax court.

    Kategorien: Tax Court
    Schlagwörter: withholding tax refund, canadian pension ...
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Björn Viebrock

Björn Viebrock

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