11. Juni 2015 5% non-deductible deemed expense for foreign dividends can i ... An ECJ advocate general has suggested the court hold that the 5% effectively connected expense add-back for foreign dividends infringes a company’s freedom of establishment if an otherwise comparable domestic company could avoid the add-back by joining a tax group. Kategorien: From EuropeSchlagwörter: foreign dividend, tax group, directly co ...
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 casesSchlagwörter: freedom of establishment, expense disall ...
02. März 2011 No bad debt deduction on tax-free sale of shares The Supreme Tax Court has held that irrecoverable proceeds from the tax-free sale of shares reduce the tax-free gain and are not a deductible bad debt. Kategorien: Supreme Tax Court casesSchlagwörter: capital gain, bad debt, default
