Suchergebnisse für: `investment-fund` (26 gefunden)

  4. 27. Mai 2014

    Foreign investment fund privilege extended

    The finance ministry has extended the period to the first accounting years ending after July 20, 2016 in which foreign investment trusts doing business in Germany on December 22, 2008, but that no longer meet the formal German registration requirements continue to be treated as though they were still recognised, provided they continue to publish their accounts in the prescribed form.

    Kategorien: Official Pronouncements
    Schlagwörter: investment funds, foreign investment tru ...
  9. 17. März 2025

    No deduction of foreign taxes for trade tax purposes within ...

    The Supreme Tax Court decided that the portfolio dividends received by the controlled company within a tax group from domestic and foreign corporations via an investment fund are subject to trade tax in full. A deduction of foreign withholding taxes in accordance with Section 34c (2) of the German Income Tax Act is not possible when determining the trade income tax basis of the tax consolidation group (Organschaft).

    Kategorien: Supreme Tax Court cases
    Schlagwörter: foreign tax credit, trade tax group
  10. 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 ...
  11. 21. August 2013

    Related party by ownership despite restrictions on exercise ...

    The Supreme Tax Court has held that internal or other restrictions on the excise of ownership rights do not obviate an association by common shareholding of more than 25%. It has also held that the application of the transfer pricing documentation rules to cross-border transactions only is, while discriminatory, justified by the need to protect tax revenue.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: related party, transfer pricing, common ...
  12. 02. Februar 2024

    Update: ECJ - Different tax treatment of resident and non-re ...

    Based on the German tax provisions existing in the years in dispute 2008 through 2010, resident and non-resident special real estate funds are treated differently, which is disadvantageous for non-resident special real estate funds. In its decision the ECJ sees a restriction on the free movement of capital which cannot be justified by overriding reasons of public interest.

    Kategorien: European Court of Justice
    Schlagwörter: investment funds
  21. Weitere laden

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Björn Viebrock

Björn Viebrock

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Düsseldorf

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