17. Juni 2015 Pre-2008 disallowance of related-party loan interest The Supreme Tax Court has held that the pre-2008 disallowance of loan interest on related-party finance for the purchase of shares refers to direct investments only. Kategorien: Supreme Tax Court casesSchlagwörter: loan interest, related party finance, th ...
08. März 2011 US profit sharing loan interest to be taxed in Germany The finance ministry has announced that application of a Supreme Tax Court judgment exempting US profit-based interest from German taxis to be seen against the treaty override provision of 2006. Kategorien: Official PronouncementsSchlagwörter: treaty override, profit sharing loan
09. September 2015 Arm’s length related-party loan interest to include risk upl ... The Supreme Tax Court has held that a write-off of an irrecoverable related-party loan is not subject to income adjustment under the arm’s length rules, although the interest rate should reflect the bad debt risk. Kategorien: Supreme Tax Court casesSchlagwörter: bad debt, related-party loan, arm's leng ...
05. Januar 2011 Loan interest subject to profits is profit sharing under Aus ... The Supreme Tax Court has held that payment of interest only if the payer remains profitable means that the payment is profit sharing and subject to withholding tax under the Austrian treaty. Kategorien: Supreme Tax Court casesSchlagwörter: loan interest, Profit-sharing interest, ...
27. Oktober 2011 Declining rate loan interest to be spread over term of the l ... The Supreme Tax Court has held that declining rate interest on a loan should be taken to prepaid expense and then written off in equal portions over the term of the loan, unless the borrower had an early repayment facility without a claim for partial refund of the higher interest paid. Kategorien: Supreme Tax Court casesSchlagwörter: early repayment, declining rate, step do ...
31. August 2011 Foreign tax credit on hedged loan interest takes hedge costs ... The Supreme Tax Court has held that the hedge costs on a foreign currency loan are to be deducted from the interest received in calculating the net foreign income as the basis for the foreign tax credit available. Kategorien: Supreme Tax Court casesSchlagwörter: loan interest, interest, foreign currenc ...
16. September 2015 Tax & Legal News – Issue 5, September 2015 In this issue: Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC. Kategorien: Tax & Legal NewsSchlagwörter: foreign tax credit, tax group, related-p ...
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 NewsSchlagwörter: Steuern / Tax
21. Juli 2011 German trade tax restriction on interest deductibility uphel ... The ECJ has upheld the German disallowance of one-half of the long-term interest expense for trade tax as not conflicting with the Interest and Royalties Directive. Kategorien: From EuropeSchlagwörter: trade tax, long-term interest, long term ...
12. Mai 2011 Trade tax interest add-back not banned by directive? An ECJ advocated general has suggested the court rule that the German trade tax interest disallowance is not a "withholding tax" banned by the Interest and Royalties Directive. Kategorien: From EuropeSchlagwörter: interest, thin capitalisation, trade tax ...
31. Oktober 2013 Foreign partner receives business income from the interest o ... The Supreme Tax Court has held that a foreign limited partner must accept attribution of the shares in a British distributor company held by the partners to the partnership. In consequence, the interest on a shareholder loan falls to the partnership, where it is requalified as trading income. The interest clause in the double tax treaty with the partner’s home country is inapplicable. Kategorien: Supreme Tax Court casesSchlagwörter: shareholder loan, partner, interest inco ...
05. Januar 2012 Tax & Legal News - Issue 1, January 2012 Includes: PwC Reports, Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC Kategorien: Tax & Legal NewsSchlagwörter: Steuern / Tax
25. April 2012 German trade tax restriction on interest deductibility uphel ... The Supreme Tax Court has upheld the German disallowance of one-half of the long-term interest expense for trade tax as not conflicting with the Interest and Royalties Directive and not infringing the German/Dutch tax treaty prohibition on discrimination. Kategorien: Supreme Tax Court casesSchlagwörter: add-back, Inerest deduction, long-term i ...
24. Oktober 2021 Supreme Tax Court rules on arm’s length interest on intercom ... In a most recent judgment, the Supreme Tax Court decided on the transfer pricing method to determine an arm's length interest on intercompany loans. In its decision the highest tax court also provides some guidelines on the parameters to be observed from a purely tax point of view. Also, the court takes time to compare the adequacy of the various standard methods under review. Kategorien: Supreme Tax Court cases, Transfer pricin ...Schlagwörter: arm's length interest, intercompany loan ...
