Suchergebnisse für: `foreign-dividend` (11 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.

   Kategorien: From Europe

   Schlagwörter: free movement of capital, foreign divide ...
2. 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
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. 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 ...
6. 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.

   Kategorien: From Europe

   Schlagwörter: foreign income, double tax relief, divid ...
7. 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.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: add-back, foreign dividend, trade tax
8. 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.

   Kategorien: Tax & Legal News

   Schlagwörter: Steuern / Tax
9. 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.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: imputation, imputation system, Foreign T ...
10. 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, ...
11. 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.

    Kategorien: From Europe

    Schlagwörter: Europäischer Gerichtshof (EuGH), Meilick ...