04. Februar 2016 Loss forfeiture exemption for troubled businesses rejected The ECJ has upheld a Commission ruling to the effect that the exemption from the provision for loss forfeiture on change of shareholders for troubled companies being rescued constitutes unlawful state aid. Kategorien: From EuropeSchlagwörter: change of shareholder, loss forfeiture, ...
05. Dezember 2017 Final circular published by Federal Ministry of Finance on a ... On 30 November 2017, the Federal Ministry of Finance published the final version of its circular on the application of the loss forfeiture rules according to Section 8c of the Corporation Tax Act (CTA), including comments on the Hidden Reserve Clause and the Group Clause. This circular replaces the circular on this subject from 4 July 2008. Kategorien: Official PronouncementsSchlagwörter: share acquisition, loss forfeiture, hidd ...
03. Juli 2018 Exemption of loss forfeiture for troubled businesses not ill ... The ECJ overturned an earlier judgment of the European General Court and held that the German tax legislation concerning the possibility of a loss-carry forward to future tax years despite a harmful share acquisition in cases of a rescue plan to save the company from insolvency – known as the salvage clause - is not illegitimate state. Kategorien: From EuropeSchlagwörter: loss forfeiture, troubled businesses, il ...
06. Dezember 2017 Tax & Legal Newsflash - 5 December 2017 Federal Finance Ministry circular on the loss forfeiture rules (Sec. 8c CTA) Kategorien: Tax & Legal NewsflashSchlagwörter: loss forfeiture rules
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 PronouncementsSchlagwörter: loss carry forward, continuance-bound ta ...
24. Juli 2013 Exemption from loss cancellation on change of shareholders m ... The ECJ has held that a Finnish exemption from a loss forfeiture provision on the change of shareholders would be state aid if the authorities may apply it with discretion and would require Commission approval if the details of the scheme have substantially changed since Finland’s accession in 1995. Kategorien: From EuropeSchlagwörter: loss cancellation, loss forfeiture, chan ...
09. Januar 2018 Tax & Legal News – Issue 1, January 2018 In this issue: PwC Reports, Official pronouncements, Tax Court Cases and From Europe Kategorien: Tax & Legal NewsSchlagwörter: anti-treaty shopping rule, troubled busi ...
23. Februar 2016 Tax & Legal News - Issue 2, February 2016 In this issue: PwC Reports, Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC Kategorien: Tax & Legal NewsSchlagwörter: Steuern / Tax
07. Februar 2018 Tax & Legal News – Issue 2, February 2018 In this issue: Official pronouncements, Tax Court Cases and From Europe Kategorien: Tax & Legal NewsSchlagwörter: Crowdfunding, pension fund, Social secur ...
03. November 2014 Tax & Legal News - Special Edition November 2014 Update ZollkodexAnpG: Bundesrat select committees ask for changes Kategorien: Tax & Legal NewsSchlagwörter: Capital gains taxation, Loss relief, Zol ...
15. Januar 2020 Cologne Tax Court - no cut-off period for applications for c ... The Cologne Tax Court held in its decision (10 V 1706/18) published on 15 January 2020, that the wording of Section 8d (1) Sentence 5 of the Act did not contain a cut-off period according to which the application under Section 8d (1) CTA for continuance-bound loss carry-forwards must be filed in the first tax return - and only there. Kategorien: Tax CourtSchlagwörter: harmful share transfers, continuance-bou ...
02. Februar 2011 Commission objects to enhanced loss relief for troubled comp ... The European Commission has concluded that the rule exempting troubled companies from the loss relief forfeiture on change of shareholders is unauthorized state aid. Kategorien: From EuropeSchlagwörter: Steuern / Tax
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: LegislationSchlagwörter: Organschaft, VAT, tax group, Cum/cum tra ...
13. Januar 2017 Amendment of tax loss utilisation rules for corporations Under certain conditions, changes in shareholders and the admission of new investors will in future be possible without giving rise to a forfeiture of losses carried-forward. On 23 December 2016 the Act for the Further Development of Tax Loss Utilisation for Corporations was published after having been adopted by the German Parliament (Bundestag and Bundesrat) on 20 December 2016. Kategorien: PwC Reports, LegislationSchlagwörter: Corporation tax, curtailment of losses, ...
19. Dezember 2014 Tax amendments 2015 finalised The Bundesrat passed a tax amendment bill on December 19, 2014 to enact a few minor changes to the tax acts for 2015. Kategorien: PwC ReportsSchlagwörter: tax ammendments
15. Oktober 2012 No abuse in sale of worthless debt to new shareholder The Supreme Tax Court has allowed a manoeuvre effectively avoiding forfeiture of a loss carry-forward on change of shareholder through the sale of a worthless shareholder loan to a new shareholder followed by recovery from the injection of new capital. Kategorien: Supreme Tax Court casesSchlagwörter: worthless debt, change of shareholder, f ...
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: LegislationSchlagwörter: Annual Tax Act 2020, Finance Bill
