Suchergebnisse für: `expense-disallowance` (5 gefunden)

1. 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 ...
2. 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 ...
3. 02. September 2015

   Full expense deduction for tax group members also for foreig ...

   The ECJ has held that provisions allowing full expense deduction within tax groups must be applied to otherwise eligible foreign subsidiaries.

   Kategorien: From Europe

   Schlagwörter: tax group, foreign subsidiaries
4. 23. Januar 2013

   Tax & Legal News – Issue 1, January 2013

   In this issue: PwC Reports, Official Pronouncments, Supreme Tax Court Cases, From Europe and From PwC

   Kategorien: Tax & Legal News

   Schlagwörter: Steuern / Tax
5. 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 Europe

   Schlagwörter: foreign dividend, tax group, directly co ...