Suchergebnisse für: `imputation` (1139 gefunden)

1. 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, foreign tax, imputation syst ...
2. 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, ...
3. 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 ...
4. 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 ...
5. 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 ...
6. 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: Foreign Tax Act, income adjustment, arm' ...
7. 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.

   Kategorien: Tax & Legal News

   Schlagwörter: Steuern / Tax
8. 26. April 2012

   Investment write-down in 2001 to be allowed

   The finance ministry has issued a decree to allow companies to write down their financial investments and marketable securities in 2001.

   Kategorien: Official Pronouncements

   Schlagwörter: investment write-down
9. 30. November 2021

   Federal Constitutional Court: Inadmissible review of norm r ...

   In a decision published on 26 November 2021, the Federal Constitutional Court (Bundesverfassungsgericht,) declared as inadmissible a referral by the Supreme Tax Court (Bundesfinanzhof) regarding Section 3 of the Solidarity Surcharge Act 1995 as amended on October 15, 2002 (SSA, 1995).

   Kategorien: Constitutional Court

   Schlagwörter: solidarity surcharge, corporate income t ...
10. 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
11. 21. März 2013

    Old corporation tax rate on German branch income of non-EU c ...

    The Supreme Tax Court has held that the corporation tax rate on the permanent establishment income of non-EU foreign companies under the old, pre-2001 system was acceptable under community law and the double tax treaty.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: permanent establishment, branch, imputat ...
12. 10. Juli 2013

    Write-down on some foreign investments permitted for 2001

    The Supreme Tax Court has held that the Corporation Tax Act prohibition on impairment write-downs on foreign investments in 2001 must be disapplied if the investment is protected by the EU freedoms of establishment or capital movement, or if it leads to retrospective taxation.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: foreign investment, write-down, impairme ...
13. 30. November 2018

    Finance Act 2018

    On 8 November 2018, the Finance Bill 2018 was adopted by the German parliament and received the consent of the Bundesrat on 23 November 2018 in the form of “The Act for the Avoidance of VAT Losses on the Trading of Goods on the Internet and Amendments to other Tax Regulations”(hereafter “Finance Act 2018”).

    Kategorien: Legislation

    Schlagwörter: Organschaft, VAT, tax group, Cum/cum tra ...
14. 16. Juni 2020

    EBA: Report and Action Plan on dividend arbitrage trading sc ...

    On 12 May 2020, the European Banking Authority - EBA - published its report on the measures and reactions of the addressed authorities in the EU Member States on dividend arbitrage trading, such as Cum/Ex and Cum/Cum schemes.

    Kategorien: Tax & Legal News

    Schlagwörter: Steuern / Tax
15. 11. April 2013

    New publication: Tax strategy and corporate reputation

    A new publication has been introduced: PwC's first Tax perspective from its 16th Annual Global CEO Survey - A focus on tax and corporate reputation.

    Kategorien: PwC Reports

    Schlagwörter: Steuern / Tax
16. 28. Dezember 2021

    EU Commission proposes swift transposition of international ...

    On 22 December 2021, the European Commission proposed a draft directive to ensure effective minimum taxation of the worldwide activities of multinational corporations.

    Kategorien: From Europe

    Schlagwörter: minimum taxation, global corporate taxat ...
17. 09. Januar 2014

    Trade tax deduction for shipping in international waters ind ...

    The Supreme Tax Court has held the 80% deduction from income chargeable to trade tax from shipping operations in international waters to be available regardless of a short or long term intention to continue the operation. If, however, the ship had already been sold prior to commissioning, the capital gain is not derived from an international operation and is chargeable to trade tax in full.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: tonnage tax, Shipping, international wat ...
18. 20. August 2020

    Federal Ministry of Finance: draft circular on the applicati ...

    The Federal Ministry of Finance has sent the draft of a Ministry circular on the application of Section 8d of the Corporation Tax Act (CTA) – continuance-bound loss carry-forward after loss forfeiture - to the professional associations for comment.

    Kategorien: Official Pronouncements

    Schlagwörter: loss carry forward, continuance-bound ta ...
19. 10. Februar 2016

    Interest limitation unconstitutional?

    The Supreme Tax Court has requested the Constitutional Court to rule on the conformity of the interest limitation with the constitutional requirement to tax like circumstances alike.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: interest limitation, EBITDA, interest ex ...
20. 04. April 2017

    Tax administration issues guidelines on cross-border coordin ...

    In light of global trading of multinational corporations the tax offices are in constant pursuit of stronger international tax compliance. The German Federal Finance Ministry has now issued guidelines on coordinated external tax audits with foreign tax administrations.

    Kategorien: Official Pronouncements

    Schlagwörter: coordinate, tax audit
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