03. Juni 2022 UPDATE: Credit of Canadian withholding tax on dividends also ... The Regional Tax Court of Hesse held that withholding tax levied in Canada on dividends distributed by a Canadian corporation to a German corporation should be credited against German trade tax. The tax authorities have in the meantime launched an appeal against this judgment and the case is now pending before the Supreme Tax Court for final clarification. Kategorien: Tax CourtSchlagwörter: withholding tax, foreign tax credit, tra ...
09. Januar 2011 Taxation of capital gains - changeover The finance ministry has ruled on a court case holding the increased capital gains scope to be unconstitutional inasfar as the gain could have been realised tax free on promulgation of the new law. Kategorien: Official PronouncementsSchlagwörter: Capital gains taxation, tax free capital ...
07. November 2013 Denial of corporation tax credit for foreign dividend justif ... An ECJ advocate general has suggested the court recognise a restriction on the free movement of capital from the differing treatment of the corporation tax underlying domestic and foreign dividends, but hold it to be justified in the interests of maintaining the internationally agreed balance of taxing rights. Kategorien: From EuropeSchlagwörter: free movement of capital, foreign divide ...
20. Juni 2017 Supreme Tax Court to refer question to European Court of Jus ... On 30 May 2017 the Supreme Tax Court decided to refer to the European Court of Justice (ECJ) the question of whether the real estate transfer tax (RETT) exemption on conversions - in Section 6a Real Estate Transfer Tax Act - constitutes illegal state aid. Kategorien: Supreme Tax Court casesSchlagwörter: real estate transfer tax, state aid, Eur ...
24. November 2017 German exclusion from withholding tax relief in conflict wit ... The German anti- treaty shopping rule denying full or partial relief from withholding tax, as otherwise prescribed under a double tax treaty or applicable EU directive, is questioned by the Lower Tax Court of Cologne as being in violation of community law. The question has been referred to the ECJ in number of cases. Kategorien: Supreme Tax Court cases, From EuropeSchlagwörter: dividend withholding tax, treaty relief, ...
