Suchergebnisse für: `dividend` (718 gefunden)

1. 09. Oktober 2012

   Brazilian interest on share capital is dividend in Germany

   The Supreme Tax Court has held the tax deductible interest on share capital under Brazilian law to rank as dividend income in Germany.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: dividend, interest on share capital
2. 18. Februar 2015

   Dividend to controlling shareholder taxable on resolution

   The Supreme Tax Court has held that a dividend payable by a solvent subsidiary to its shareholder with a controlling interest is generally taxable income for the latter on the date of the resolution regardless of a resolution for a later date of payment.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: dividend, controlling interest, resoluti ...
3. 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
4. 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
5. 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
6. 22. November 2012

   Dividend withholding tax does not disadvantage foreign pensi ...

   The ECJ has rejected a claim by the Commission that the German withholding tax on gross dividends discriminates against foreign pension funds, because the Commission did not substantiate the expenses excluded from deduction.

   Kategorien: From Europe

   Schlagwörter: pension fund, dividend withholding tax, ...
7. 21. Oktober 2011

   Germany’s dividend withholding tax hinders free movement of ...

   In a case brought by the Commission, the ECJ has held that Germany’s withholding tax on dividends to other corporations is in breach of community law in that it discourages persons from other member states from investing in Germany.

   Kategorien: From Europe

   Schlagwörter: free movement of capital, dividend withh ...
8. 18. Februar 2015

   No requalification of share capital repayment to dividend if ...

   The Supreme Tax Court has rejected a tax office attempt to requalify a repayment of share capital as a dividend merely because the repayment was not specified precisely in the capital reduction Resolution.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: share capital, repayment, capital reduct ...
9. 07. November 2013

   Denial of corporation tax credit for foreign dividend justif ...

   An ECJ advocate general has suggested the court recognise a restriction on the free movement of capital from the differing treatment of the corporation tax underlying domestic and foreign dividends, but hold it to be justified in the interests of maintaining the internationally agreed balance of taxing rights.

   Kategorien: From Europe

   Schlagwörter: free movement of capital, foreign divide ...
10. 15. November 2012

    5% dividend expense disallowance restricts freedom of establ ...

    The Supreme Tax Court has held that the 5% expense disallowance on tax-free dividends was, up to 2002, a restriction on the freedom of establishment rather than of capital movement and could thus be upheld in respect of a 33% share in a US company.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: freedom of establishment, expense disall ...
11. 16. Juni 2020

    EBA: Report and Action Plan on dividend arbitrage trading sc ...

    On 12 May 2020, the European Banking Authority - EBA - published its report on the measures and reactions of the addressed authorities in the EU Member States on dividend arbitrage trading, such as Cum/Ex and Cum/Cum schemes.

    Kategorien: Tax & Legal News

    Schlagwörter: Steuern / Tax
12. 29. Januar 2019

    Trade tax: Dividend income exemption in case of double resid ...

    According to the Lower Tax Court of Hesse, the dividend income exemption for trade tax on qualifying shareholdings is also available for distributions of companies of foreign legal form - provided the foreign company is comparable to a German corporation, has its place of management and thus a permanent establishment in Germany.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: dividend exemption, trade tax exemption, ...
13. 05. Januar 2011

    Intercorporate dividends from Norway confirmed as tax-free

    The finance ministry has confirmed its interpretation of the Norwegian DTT to the effect that dividends received by a German company on a holding of 25% or more are free of German taxation.

    Kategorien: Official Pronouncements

    Schlagwörter: double tax treaty, Intercorporate divide ...
14. 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
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, portuguese dividend withholding t ...
16. 31. Januar 2018

    German taxation of dividends paid to Canadian pension fund i ...

    The Lower Tax Court of Munich referred preliminary questions to the European Court of Justice regarding the compatibility of the German regime of dividend withholding tax imposed on a Canadian pension fund with the free movement of capital as provided in Article 63 of the Treaty on the Functioning of the European Union.

    Kategorien: European Court of Justice

    Schlagwörter: pension fund, dividend withholding tax, ...
17. 09. Juli 2013

    Withholding tax exemption on dividends on shares held in ban ...

    The finance ministry has announced the arrangements for claiming withholding tax exemption under the EU Parent/Subsidiary Directive on dividends on shares held in the custody of a bank.

    Kategorien: Official Pronouncements

    Schlagwörter: withholding tax, dividend, Parent/Subsid ...
18. 18. März 2015

    No trade tax disallowance of expenses of earning tax-free di ...

    The Supreme Tax Court has held that there is ultimately no trade tax disallowance of expenses directly connected with tax-free dividend income earned through an Organschaft subsidiary.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: trade tax disallowance, tax-free dividen ...
19. 01. Dezember 2021

    Dividend exemption under double tax treaty or abuse of legal ...

    The distribution of profits by a Luxembourg subsidiary (in the legal form of a SARL) to its German parent company (a partnership limited by shares – KGaA) may be an abuse of legal forms where the KGaA provided SARL with a loan and shortly thereafter waived repayment, thereby putting SARL in a position to actually make the profit distribution. Even more when the losses arising from the impairment of the value of SARL because of the distribution are to be used by the shareholders in a tax-effective manner.

    Kategorien: Tax Court

    Schlagwörter: dividend exemption, abuse of legal forms ...
20. 30. Juni 2011

    Maximum imputation credit for foreign tax is amount paid

    The ECJ has held that the foreign tax imputation credit on a dividend received from abroad is the lower of the corporation tax shown to have been paid abroad and the income tax due on the dividend by recipient.

    Kategorien: From Europe

    Schlagwörter: Meilicke, imputation, foreign dividend, ...
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