Suchergebnisse für: `dynamic-reference` (2 gefunden)

1. 11. Januar 2021

   Review of profit and loss pooling agreements concluded prior ...

   An amendment to a statutory law which was passed by the Bundestag and Bundesrat in December 2020, entered into force on 1 January 2021, requires a review of those profit and loss pooling agreements concluded and last amended before 27 February 2013. This pertains to profit and loss pooling agreements (PLPA) for tax groups (“Organschaft”) with a GmbH as controlled subsidiary and which do not (yet) contain an explicit and unconditional reference to Section 302 of the German Stock Corporation Act (GSCA) which includes future changes of the provision (so-called “dynamic reference”).

   Kategorien: PwC Reports

   Schlagwörter: Organschaft, profit and loss transfer ag ...
2. 10. November 2017

   Tax Consolidation Groups (“Organschaft”) for income tax purp ...

   According to a decision of the Supreme Tax Court published on 9 November 2017 a profit pooling agreement will not be recognised for tax purposes where the compensation agreement with the external shareholder contains both the right to a variable compensation payment calculated on the basis of the profits of the subsidiary/controlled company/"Organgesellschaft" (“subsidiary”) and a fixed amount.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Organschaft, Corporation tax, compensati ...