Suchergebnisse für: `foreign-dividend` (25 gefunden)

1. 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. ... Foreign dividends, by contrast were exempted from corporation tax, and for that reason no credit was

   Kategorien: From Europe

   Schlagwörter: free movement of capital, foreign divide ...
2. 10. Juli 2013

   No trade tax add-back for foreign dividends in 2001

   The Supreme Tax Court has held that the provision in the Trade Tax Act requiring that foreign dividends on shareholdings of up to 10% be charged to tax if received in 2001 is contrary to European law and must be disapplied for that year. ... The ECJ has already held that a distinction in the tax treatment of domestic and foreign dividends can

   Kategorien: Supreme Tax Court cases

   Schlagwörter: add-back, foreign dividend, trade tax
3. 23. Februar 2011

   Foreign dividend capital repayment if so classified in home ...

   The Supreme Tax Court has held that a US distribution of shares in a former subsidiary is a tax-free capital repayment to a German resident shareholder if so classified under US law.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Steuern / Tax
4. 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 ...
5. 10. Juni 2015

   Imputation credit for foreign corporation tax refused

   Despite apparently favourable ECJ judgments, the Supreme Tax Court has once again refused a taxpayer credit for the foreign corporation tax due on a dividend received during the currency of the old, imputation tax System. ... Foreign dividends were outside it; a foreign dividend was exempt for a company but taxable on its nominal

   Kategorien: Supreme Tax Court cases

   Schlagwörter: imputation, foreign tax, imputation syst ...
6. 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. ... The Supreme Tax Court has followed this judgment in the present case, holding that the foreign dividend

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Steuern / Tax
7. 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. ... The Supreme Tax Court has followed this judgment in the present case, holding that the foreign dividend

   Kategorien: Supreme Tax Court cases

   Schlagwörter: withholding tax, refund, dividend
8. 16. September 2014

   Differing forms of double tax relief not restriction on free ...

   The ECJ has held that no restriction on the freedom of capital movement arises from relieving domestic double taxation on dividend income under an exact imputation system, whilst foreign double taxation is relieved by exempting the foreign income. ... dividend from a further, domestic charge.

   Kategorien: From Europe

   Schlagwörter: foreign income, double tax relief, divid ...
9. 16. Januar 2014

   Tax & Legal News – Issue 1, January 2014

   In this issue: PwC Reports, Official Pronouncments, Supreme Tax Court Cases, From Europe and From PwC. ... Denial of corporation tax credit for foreign dividend justified by systematic differences?

   Kategorien: Tax & Legal News

   Schlagwörter: Steuern / Tax
10. 17. Januar 2011

    Corporation tax imputation credit – round two

    An ECJ advocate general has suggested the court give rather general guidance on the calculation and verification of the creditable corporation tax underlying a dividend from another EU country. ... Here, the advocate general contents herself with the conclusion that a foreign dividend recipient should

    Kategorien: From Europe

    Schlagwörter: EuGH, Meilicke, Corporation tax, ECJ
11. 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. ... Foreign dividends were excluded from the imputation mechanism and were therefore effectively taxed twice

    Kategorien: From Europe

    Schlagwörter: Meilicke, imputation, foreign dividend, ...
12. 13. August 2015

    Tax & Legal News – Issue 4, August 2015

    In this issue: PwC Reports, Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC. ... dividends can infringe freedom of establishment?

    Kategorien: Tax & Legal News

    Schlagwörter: Steuern / Tax
13. 19. Juli 2016

    No deduction of foreign withholding tax in case of abuse

    Dividend withholding tax paid by a foreign intermediary company may not be deducted from the taxable income of the local shareholder of a German company if the entire arrangement is abusive and if, therefore, the dividend income is to be allocated to the German shareholder. ... Specifically, withholding taxes on certain foreign dividends may be credited against the German income

    Kategorien: Supreme Tax Court cases

    Schlagwörter: abuse, foreign tax relief, deduction of ...
14. 15. Oktober 2013

    Tax & Legal News – Issue 4, October 2013

    In this issue: PwC Reports, Official Pronouncments, Supreme Tax Court Cases, From Europe and From PwC. ... dividends in 2001 Real estate transfer tax basis reduced if conveyancing costs borne by seller No RETT

    Kategorien: Tax & Legal News

    Schlagwörter: state aid, subject to tax, employee opti ...
15. 17. Mai 2019

    Tax exemption on gains from share disposals available to fin ...

    Gains realised by financial undertakings resident in third countries on the disposal of shares are fully exempt from corporation tax. In these proceedings,the Hessian Tax Court considered whether the exclusion from the benefit of the participation exemption under Section 8b (7) of the Corporation Tax Act also applied to credit institutions and financial services institutions not resident in the EU/EEA. ... dividends and gains on disposals of shares.

    Kategorien: Tax Court

    Schlagwörter: financial undertakings, banks, participa ...
16. 14. November 2012

    Foreign tax credit precluded if domestic income exempt despi ...

    The ECJ has held that freedoms of establishment and of capital movement preclude national legislation relieving foreign tax by credit as opposed to the exemption of domestic source income where the actual corporation tax paid by domestic companies is generally less than the nominal rate. It has also accepted the freedom of capital movement as relevant, unless the national legislation was aimed at controlling interests. ... By contrast, the tax credit granted on foreign dividends is limited to the lower of the foreign tax actually

    Kategorien: From Europe

    Schlagwörter: foreign tax credit, freedom of establish ...
17. 18. Mai 2011

    Rental income of foreign residents

    The finance ministry has issued an explanatory decree for foreign businesses following a change in the law reclassifying their income from German property from rental to trading income.

    Kategorien: Official Pronouncements

    Schlagwörter: rental income, foreign residents, bookke ...
18. 22. März 2019

    Unlimited tax liability with dual residency

    The fact that a taxpayer has both a residence in Germany and a residence abroad does not, according to a ruling by the Supreme Tax Court, preclude the existence if an unlimited tax liability even when the foreign residence constitutes the centre of the taxpayer’s vital interests

    Kategorien: Supreme Tax Court cases

    Schlagwörter: centre of vital interests, limited taxpa ...
19. 26. Juni 2018

    Current version of German anti-treaty shopping legislation i ...

    On 25 June 2018, the European Court of Justice published its decision of 14 June 2018 concerning the current version of the German anti-treaty /anti-directive shopping legislation.

    Kategorien: European Court of Justice

    Schlagwörter: freedom of establishment, Parent/Subsidi ...
20. 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
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