Suchergebnisse für: `investment-fund` (36 gefunden)

  3. 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. ... Foreign investment funds that no longer meet enhanced registration requirements for doing business in

    Kategorien: Official Pronouncements
    Schlagwörter: investment fund, foreign investment trus ...
  4. 27. März 2014

    No refusal of relief under tax deferral scheme rules for unp ...

    The Supreme Tax Court has held that a loss incurred on an investment project of a closed-circle investment fund can be deducted by investors from their other income if the loss was not pre-planned and factored into the fund’s yield calculations. ... The management company of an investment fund in equipment leasing objected to the tax office’ description

    Kategorien: Supreme Tax Court cases
    Schlagwörter: investment fund, tax deferral scheme
  6. 11. Oktober 2014

    Arbitrary tax on “non-transparent” investment funds rejected

    The ECJ has rejected the estimated taxation of “non-transparent” investment funds as excessive taxation hindering the freedom of capital movement on shares held in foreign investment funds that do not report und publish their results in Germany in accordance with German law. ...  The Investment Fund Tax Act basically taxes investors on their dividends and accrued income (reinvested

    Kategorien: From Europe
    Schlagwörter: investment fund, non-transparent
  8. 06. August 2015

    Income documentation exemption for non-transparent investmen ...

    The finance ministry has clarified that its decree of February 4, 2015 on the documentation requirements to be met by resident investors in non-transparent foreign investment funds applies to funds located in other EEA countries only. ... Under the Investment Funds Tax Act, 6% of the value of the units at year-end is deemed to be the minimum

    Kategorien: Official Pronouncements
    Schlagwörter: investment fund, non-transparent, minimu ...
  10. 21. Mai 2015

    Estimated taxation on deemed income from non-transparent inv ...

    The ECJ has held that a German provision for the taxation of deemed income from foreign investment funds outside the EU that do not comply with the German disclosure requirements falls under the “grandfather” clause of Art 64 of the TFEU allowing restrictions on the free movement of capital to and from third countries on December 31, 1993 to continue in force. ... German law taxes unit holders in foreign investment funds that do not fully comply with the German disclosure

    Kategorien: From Europe
    Schlagwörter: free movement of capital, investment fun ...
  13. 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. ... A partnership purchased a merchant ship with the intention of selling her to an investment fund, once

    Kategorien: Supreme Tax Court cases
    Schlagwörter: tonnage tax, Shipping, international wat ...
  14. 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. ... The investment fund management company was obliged to follow the policies of the fund.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: related party, transfer pricing, common ...
  19. 17. März 2017

    Write-downs to fair market value resulting from foreign exch ...

    Where a company, which has acquired investment units in US dollar denominated equity funds, writes down the value of the investment units to their fair market value following an unfavourable development in the foreign currency exchange rate, the company must add the write down back off-balance sheet. ... fund goes down, but also where the value of the shares at the balance sheet date has sunk because of

    Kategorien: Supreme Tax Court cases
    Schlagwörter: Corporation tax, Off-balance sheet add b ...
  20. 19. November 2021

    Supreme Tax Court: Income from convertible bonds subject to ...

    Interest received by a US limited liability company from convertible bonds issued by a German debtor is subject to German withholding tax pursuant to Sec. 49 (1) No. 5 letter a Income Tax Act. This also applies if partial debentures were issued for these bonds. With its decision, the Supreme Tax Court put an end to the existing discussions and differing opinions in the professional literature regarding the correlation of two provisions in the Income Tax Act on that subject. ... fund units, if the debtor has a German residence, management, or seat.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: limited tax liability, convertible bonds ...
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