Suchergebnisse für: `limited-tax-liability` (16 gefunden)

1. 23. Mai 2018

   Pensions paid abroad subject to limited tax liability

   A limited tax liability on payments by the German State pension fund to a resident of Canada is not nullified by the tax treaty.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: tax treaty, pensions, Income tax, limite ...
2. 13. Dezember 2021

   Extended limited tax liability if income is subject to U.K. ...

   A taxpayer resident in the U.K. who exercises his right under U.K. tax law  to pay tax on income not earned in the U.K. on a "remittance basis" is caught by the preferential taxation regime of Sec. 2 (2) No. 2 Foreign Tax Act and subject to extended limited tax liability in Germany.

   Kategorien: Tax Court

   Schlagwörter: preferential taxation, extended limited ...
3. 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: Foreign Tax Act, discrimination, former ...
4. 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.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: limited tax liability, convertible bonds ...
5. 08. Juli 2022

   Limited tax liability and tax withholding in case of indefin ...

   The transfer of know-how by a foreign creditor for an unlimited period may lead to limited income tax liability in Germany by way of tax withholding. The fact that the know-how must be used domestically in order to trigger German withholding tax does, according to the Supreme Tax Court, not require that the know-how also had the specified scope, substance and quality to fulfill the purposes pursued in the domestic market.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: withholding tax, limited tax liability
6. 08. Februar 2022

   Rules for limited inheritance tax liability only in part com ...

   According to the decision of the European Court of Justice (ECJ), the different inheritance tax allowances in the case of unlimited and limited tax liability is in line with EU law, specifically it is not in breach of the free movement of capital. However, the refusal of the German tax office to deduct liabilities linked to the inheritance in the case of limited tax liability is not compatible with EU law. 

   Kategorien: European Court of Justice

   Schlagwörter: limited inheritance tax liability, inher ...
7. 31. Dezember 2020

   No option for full tax assessment by U.S. citizen living in ...

   According to a judgment of the Supreme Tax Court, a U.S. citizen with limited tax liability in Germany is not entitled to the right of full tax assessment for income from employment even if he lives in an EU or EEA state (here: the Netherlands). The non-discrimination clause in Article 24 of the German/US double tax treaty does not give rise to a claim to equal treatment with a German national with limited tax liability.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: employment income, tax assessment, limit ...
8. 26. Juni 2018

   Tax & Legal News - Issue 4, June 2018

   Some of the topics in this issue: Administration amends circular on treaty-shopping rules, Pensions paid abroad subject to limited tax liability, ECJ - Denmark to set-off final losses of foreign EU-branch.

   Kategorien: Tax & Legal News

   Schlagwörter: Final PE losses, anti-treaty shopping ru ...
9. 10. Dezember 2015

   Tax & Legal News – Issue 7, December 2015

   In this issue: Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC

   Kategorien: Tax & Legal News

   Schlagwörter: Steuern / Tax
10. 28. November 2017

    Limited taxpayers: withholding tax on cross-border licensing ...

    At the beginning of November 2017 the Federal Finance Ministry published the long-awaited circular on its intended application of the rules (Section 50a Income Tax Act)applying to limited taxpayers and withholding tax on cross-border licensing of software and databanks.

    Kategorien: Official Pronouncements

    Schlagwörter: International Tax, administrative princi ...
11. 02. Juni 2022

    Tax Relief Act 2022 enters into force

    The Tax Relief Act 2022 was published on 31 May 2022 and has thus entered into force.

    Kategorien: Official Pronouncements, Legislation

    Schlagwörter: Income Tax Act
12. 16. März 2017

    Interest paid by foreign partner deductible also in case of ...

    In a decision published in March 2017 the Supreme Tax Court held that - in the case of a two-tier partnership structure – the interest expense of the Dutch partner holding only an indirect share in a German limited partnership is nevertheless tax deductible when computing his limited German tax liability resulting from his investment in the German partnership.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: limited partnership, Two-Tier Partnershi ...
13. 14. November 2019

    Bundestag approve Finance Act 2019

    On 7 November 2019, the Bundestag approved the Act on the Further Tax Promotion of Electric Mobility and the Amendment of Further Tax Regulations (Finance Act 2019 – “FA19”) in the version recommended by the Finance Committee of the Bundestag.

    Kategorien: Official Pronouncements, Legislation

    Schlagwörter: electric mobility, Finance Bill
14. 22. März 2019

    Unlimited tax liability with dual residency

    The fact that a taxpayer has both a residence in Germany and a residence abroad does not, according to a ruling by the Supreme Tax Court, preclude the existence if an unlimited tax liability even when the foreign residence constitutes the centre of the taxpayer’s vital interests

    Kategorien: Supreme Tax Court cases

    Schlagwörter: centre of vital interests, limited taxpa ...
15. 27. September 2016

    Packet of measures against profit reduction and profit shift ...

    At a sitting on 23 September 2016, the Federal Assembly (Bundesrat) has responded to the draft of the Act to Implement the Amendments to the EU Mutual Assistance Directive and to Introduce Further Measures to Combat Profit Reduction and Profit Shifting (“the draft Act”) and proposed further measures.

    Kategorien: PwC Reports

    Schlagwörter: EU Mutual Assistance Directive, Profit R ...
16. 28. Dezember 2020

    German Bundesrat approved Finance Bill 2020

    In its plenary session of 18 December 2020 the Bundesrat approved the Finance Bill 2020.

    Kategorien: Legislation

    Schlagwörter: Annual Tax Act 2020, Finance Bill