Suchergebnisse für: `foreign-taxes-act` (22 gefunden)

1. 01. Juli 2022

   Income adjustment pursuant to Section 1 (1) FTA vis-à-vis a ...

   Following a referral from the Federal Constitutional Court, the Supreme Tax Court has again had to rule on the income adjustment pursuant to Section 1 (1) Foreign Taxes Act vis-à-vis the write-down of an unsecured loan receivable issued within a group

   Kategorien: Supreme Tax Court cases, Constitutional ...

   Schlagwörter: income adjustment, International Tax, un ...
2. 14. August 2025

   Federal Ministry of Finance publishes draft bill for a Minim ...

   On August 6, 2025, the Federal Ministry of Finance (MoF) sent the draft bill for a law to adjust the Minimum Tax Act (“MTA”) and implement further measures (“MTAA – Draft”) to the associations for comment by August 11, 2025. The draft bill includes measures for the implementation of the OECD Administrative Guidance on Article 9.1 of the Global Anti-Base Erosion Model Rules from January 2025 as well as “accompanying measures" that are intended to contribute to the simplification of international tax law ("decluttering") outside the scope of the MTA.

   Kategorien: Official Pronouncements, Tax & Legal New ...

   Schlagwörter: CFC provisions, minimum taxation, Foreig ...
3. 29. November 2022

   Finance Bill 2022 - Introduction of a so-called "windfall ta ...

   The Federal Ministry of Finance (MoF) has provided the Finance Committee of the Bundestag several formulation aids for its ongoing consultations on the Finance Bill 2022.

   Kategorien: Legislation

   Schlagwörter: Inflation, Income Tax Act, corporate inc ...
4. 18. Januar 2019

   Trade tax: foreign passive income attribution

   Two decisions of the Baden-Württemberg Tax Court have been published in connection with the attribution of foreign passive income for trade tax purposes. In these decisions the Court also raises doubts as to whether the add-back of this type of foreign income is compatible with EU law.

   Kategorien: Tax Court

   Schlagwörter: trade tax, CFC, trade tax deduction, for ...
5. 05. April 2016

   No conflict between Foreign Tax Act and tax treaty definitio ...

   The finance ministry has decreed that Supreme Tax Court judgments limiting the income adjustments under the Foreign Tax Act to questions of amount are not to be followed as precedents prohibiting adjustments by reason of the nature of the transaction under review.

   Kategorien: Official Pronouncements

   Schlagwörter: income adjustment, arm's length, Foreign ...
6. 18. Dezember 2018

   Draft bill - Brexit Ancillary Regulations

   On 13 December 2018 the Federal Ministry of Finance published a draft bill for the enactment of tax and other regulations for Brexit (“Brexit Bill”)designed to alleviate certain legal consequences arising by reason of Brexit alone.

   Kategorien: Legislation

   Schlagwörter: Brexit
7. 09. Januar 2011

   Active business can be contracted out

   The Supreme Tax Court has held that a Dublin docks reinsurance company that subcontracted its operation under a management agreement was an active business within the meaning of the Foreign Tax Act.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Active business, contracted out, CFC pro ...
8. 15. April 2024

   ドイツ経済成長促進法の可決

   2024年3月22日、連邦参議院は厳しい交渉の末、経済成長促進法（独: Wachstumschancengesetz 英: Growth Opportunities Act）の法案について調停委員会の妥協案を承認しました。 本稿では在独日系企業に影響が出ると考えられる項目に内容を限定して解説します。

   Kategorien: Japan Business Network (JBN) Newsflash

   Schlagwörter: Japan
9. 09. Juni 2021

   UPDATE : Bundestag passes the Act to Modernise the Relief of ...

   On 5 May 2021, the Bundestag passed the Act to Modernise the Relief of Withholding Taxes and the Certification of Capital Gains Tax. The law as passed is based on the resolution recommended and passed by the Bundestag Finance Committee on 21 April 2021.

   Kategorien: Legislation

   Schlagwörter: ATAD, dividend withholding tax, Income T ...
10. 19. November 2015

    ECJ confirms German extended limited tax liability

    The ECJ has held that the continued liability to German tax on German sources income of a former resident is not discrimination prohibited by community law.

    Kategorien: From Europe

    Schlagwörter: discrimination, former resident, Foreign ...
11. 26. November 2014

    Income adjustment for interest-free loan to foreign subsidia ...

    The Supreme Tax Court has held that an income adjustment for the interest lost on an interest-free loan to a foreign subsidiary can be made under the Foreign Tax Act unless the loan was granted as a substitute for share capital.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: income adjustment, interest-free loan, f ...
12. 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 ...
13. 06. November 2019

    CFC rules considered to be in line with EU law

    Following a ruling by the European Court of Justice (ECJ) earlier this year, the Supreme Tax Court held in its decision of 31 October 2019 that the incorporation into the tax base of controlled company income from invested capital from an intermediary company domiciled in Switzerland in the financial year 2006 may restrict the free movement of capital, but it is justified through compelling reasons of public interest and does not therefore contravene EU law.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: CFC provisions, free movement of capital ...
14. 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, ...
15. 21. November 2023

    Bundestag approves Growth Opportunities Act

    On 17 November 2023, the Bundestag approved the Act to Strengthen Growth Opportunities, Investment, and Innovation as well as Tax Simplification and Fairness (Growth Opportunities Act) in the form recommended by its Finance Committee. The Act will be presented to the Bundesrat on 24 November 2023. It cannot currently be ruled out that the Bundesrat will convene the Mediation Committee to discuss individual provisions of the Act (the climate protection investment premium, in particular, will probably be discussed).

    Kategorien: Official Pronouncements, Tax & Legal New ...

    Schlagwörter: Corporation tax, Income Tax Act, Growth ...
16. 12. Juli 2023

    Ministry of Finance publishes draft bill on the implementati ...

    On Monday, 10 July 2023, the Federal Ministry of Finance sent the draft bill for the implementation of the Directive to ensure a global minimum level of taxation for multinational enterprise groups and large domestic groups in the Union (so-called Minimum Taxation Directive Implementation Act – “Implementation Bill”) to the associations with the request for comment by 21 July 2023.

    Kategorien: Tax & Legal News, Legislation

    Schlagwörter: Pillar Two, minimum taxation, EU-Directi ...
17. 15. Dezember 2023

    Bundesrat approves a partial implementation of the Growth Op ...

    On 15 December 2023, the Bundesrat approved the partial implementation of the contents of the Growth Opportunities Act in the Act to Promote the Secondary Credit Market. This includes changes to the interest limitation rule and adjustments resulting from the introduction of the Act for the Modernisation of Partnerships.

    Kategorien: Official Pronouncements, Legislation

    Schlagwörter: real estate transfer tax, thin capitalis ...
18. 05. September 2023

    Federal Cabinet approves government draft of the Growth Oppo ...

    At its closed-door meeting in Meseberg on 30.8.2023, the Federal Cabinet adopted the government draft for a law to enhance growth opportunities, investment, and innovation as well as tax simplification and tax fairness (Growth Opportunities Act).

    Kategorien: Tax & Legal News, Legislation

    Schlagwörter: Climate Change, interest limitation, RET ...
19. 27. Februar 2024

    Growth Opportunities Act: Dispute to continue despite compro ...

    In its session of 21 February 2024, the Mediation Committee of the Bundestag and Bundesrat concluded its negotiations in relation to the Act to Strengthen Growth Opportunities, Investment, and Innovation as well as Tax Simplification and Fairness

    Kategorien: Official Pronouncements, Tax & Legal New ...

    Schlagwörter: Corporation tax, trade tax, Income Tax A ...
20. 07. Juni 2024

    Federal Cabinet approves government draft of the Finance Act ...

    At its meeting on 5 June 2024, the Federal Cabinet adopted a government draft for the Finance Act 2024 (FA 2024). Despite numerous revisions, the material amendments from the original draft from 8 May 2024 have been limited. The main changes are shown in italics and red in the following summary of the government draft in italics and red.

    Kategorien: Official Pronouncements, Tax & Legal New ...

    Schlagwörter: Real Estate, trade tax, General Tax Code ...
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