Suchergebnisse für: `harmful-share-acquisition` (4 gefunden)

1. 03. Juli 2018

   Exemption of loss forfeiture for troubled businesses not ill ...

   The ECJ overturned an earlier judgment of the European General Court and held that the German tax legislation concerning the possibility of a loss-carry forward to future tax years despite a harmful share acquisition in cases of a rescue plan to save the company from insolvency – known as the salvage clause - is not illegitimate state aid.

   Kategorien: From Europe

   Schlagwörter: loss forfeiture, troubled businesses, il ...
2. 05. Dezember 2017

   Final circular published by Federal Ministry of Finance on a ...

   On 30 November 2017, the Federal Ministry of Finance published the final version of its circular on the application of the loss forfeiture rules according to Section 8c of the Corporation Tax Act (CTA), including comments on the Hidden Reserve Clause and the Group Clause. This circular replaces the circular on this subject from 4 July 2008.

   Kategorien: Official Pronouncements

   Schlagwörter: share acquisition, loss forfeiture, hidd ...
3. 21. September 2016

   Loss carry back in case of change in shareholding during the ...

   The Lower Tax Court of Muenster held that losses incurred during the year in which a harmful change in shareholding took place can be carried back to the previous tax year.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: loss carry-back, change of shareholders, ...
4. 07. November 2025

   Losses incurred prior to harmful acquisition may be carried ...

   The Supreme Tax Court decided that negative income from the financial year in which a harmful acquisition of shares within the meaning of Section 8c Corporation Tax Act takes place is not completely barred as it still can be offset (carried back) against income from the previous year to the extent the losses were incurred prior to the harmful share transfer.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: loss carry-back, harmful share acquisiti ...