29. November 2012 “Minimum taxation” constitutional The Supreme Tax Court has held the “minimum taxation” deferral of loss relief to be constitutionally acceptable. Kategorien: Supreme Tax Court casesSchlagwörter: Loss relief, minimum taxation, minimum t ...
25. Mai 2011 1999 minimum taxation rules do not affect loss carry-back to ... The Supreme Tax Court has held that the 1999 introduction of “minimum taxation” rules limiting loss offset by income type do not apply to a 1999 loss carried back to 1998. Kategorien: Supreme Tax Court casesSchlagwörter: minimum taxation, loss offset, loss carr ...
24. Mai 2019 German Finance Minister talks “minimum taxation” According to various statements of the German Finance Minister Olaf Scholz on 22 May 2019, a system of international minimum taxation will be discussed at the forthcoming G20 (June 2019) and G7 (August 2019) meetings. The aim is to agree such a system (within the terms of the Global Anti-Base Erosion "GloBE" agenda and given the name “BEPS 2.0”) with the other 128 states of the OECD in the Summer of 2020. Kategorien: Official PronouncementsSchlagwörter: OECD, BEPS, minimum taxation, under-taxe ...
28. Dezember 2021 EU Commission proposes swift transposition of international ... On 22 December 2021, the European Commission proposed a draft directive to ensure effective minimum taxation of the worldwide activities of multinational corporations. Kategorien: From EuropeSchlagwörter: minimum taxation, global corporate taxat ...
12. Juli 2023 Ministry of Finance publishes draft bill on the implementati ... On Monday, 10 July 2023, the Federal Ministry of Finance sent the draft bill for the implementation of the Directive to ensure a global minimum level of taxation for multinational enterprise groups and large domestic groups in the Union (so-called Minimum Taxation Directive Implementation Act – “Implementation Bill”) to the associations with the request for comment by 21 July 2023. Kategorien: Tax & Legal News, LegislationSchlagwörter: Pillar Two, minimum taxation, EU-Directi ...
01. September 2023 Government bill for a law to implement the global minimum ta ... On Wednesday, 16 August 2023, the Federal Cabinet adopted the government's draft bill on the implementation of Council Directive (EU) 2022/2523 to ensure minimum global taxation with other accompanying measures. The draft was officially published on 17 August 2023 Kategorien: LegislationSchlagwörter: OECD, Pillar Two, minimum taxation, EU-D ...
15. April 2015 Minimum taxation not a reason for provisional assessment The Supreme Tax Court has held that a tax office cannot be required to issue a provisional assessment restricting the immediate deduction of the loss brought forward, merely because of the possibility that the remaining loss to be carried forward might be invalidated by a share transaction abroad at some future point in time. Kategorien: Supreme Tax Court casesSchlagwörter: loss offset, minimum tax, provisional as ...
25. Mai 2011 Loss offset limitation 1999-2003 only applies to notional lo ... The Supreme Tax Court has held that the 1999-2003 “minimum taxation” rules apply to “paper” losses, but not to those borne with true economic effect. Kategorien: Supreme Tax Court casesSchlagwörter: minimum taxation, loss offset
15. Dezember 2023 UPDATE: Update: Bundesrat approves introduction of a global ... On 10 November 2023, the Bundestag passed the draft bill submitted by the German government on the EU directive on global minimum taxation. The vote was based on a recommendation by the Finance Committee. Kategorien: Tax & Legal News, LegislationSchlagwörter: anti-avoidance, global minimum tax, EU-D ...
12. September 2022 Federal Ministry of Finance: joint statement on global mini ... At an informal meeting in Prague, the finance ministers of France, Spain, Italy, the Netherlands and Germany published a joint statement on global effective minimum taxation ("Pillar 2"). Kategorien: Tax & Legal NewsSchlagwörter: Pillar Two, ECOFIN, global minimum tax
21. März 2023 Tax Insights from Global Structuring - Germany publishes Pil ... The Federal Ministry of Finance (MoF) published a draft law on March 20, to implement the ‘Pillar Two’ Directive ensuring a global minimum taxation for multinational groups and large domestic groups in the European Union (so-called Minimum Tax Directive Implementation Act - MinBestRL-UmsG). The publication of the German draft law follows the formal adoption by the EU Council to adopt Pillar Two on December 15, 2022. Kategorien: Legislation, Tax & Legal NewsflashSchlagwörter: Gesetzgebung, EU-Recht, Pillar Two
27. März 2013 First €1 m full loss offset for each period of assessment The Supreme Court has held that the initial full loss offset on €1 m applies to each period of assessment, rather than to each calendar year. Thus it can only be claimed once for a multi-year assessment. Kategorien: Supreme Tax Court casesSchlagwörter: Liquidation, minimum taxation, loss offs ...
03. September 2014 Loss offset deferral unconstitutional? The Supreme Tax Court has referred to the Constitutional Court on whether a confiscatory effect of the loss offset deferral provisions can be a breach of the equal treatment requirement of the constitution. Kategorien: Supreme Tax Court casesSchlagwörter: minimum taxation, loss offset
19. April 2025 EU Council: Rules to extend cooperation and information exch ... On 14 April 2025 the Council adopted a directive (DAC9) that will extend cooperation and information exchange in the area of minimum effective corporate taxation. Kategorien: From EuropeSchlagwörter: minimum taxation, information exchange
03. Juni 2015 Tax & Legal News – Issue 3, June 2015 In this issue: PwC Reports, Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC Kategorien: Tax & Legal NewsSchlagwörter: inheritance tax, roll-over relief provis ...
23. Januar 2013 Tax & Legal News – Issue 1, January 2013 In this issue: PwC Reports, Official Pronouncments, Supreme Tax Court Cases, From Europe and From PwC Kategorien: Tax & Legal NewsSchlagwörter: Steuern / Tax
05. September 2023 Federal Cabinet approves government draft of the Growth Oppo ... At its closed-door meeting in Meseberg on 30.8.2023, the Federal Cabinet adopted the government draft for a law to enhance growth opportunities, investment, and innovation as well as tax simplification and tax fairness (Growth Opportunities Act). Kategorien: Tax & Legal News, LegislationSchlagwörter: Climate Change, interest limitation, RET ...
15. Juni 2011 Minimum rate for non-residents with business income confirme ... The Supreme Tax Court has confirmed that a minimum tax rate levied on non-residents earning business income in Germany does not offend against the non-discrimination clauses of international treaties. Kategorien: Supreme Tax Court casesSchlagwörter: non-residents, minimum rate
20. Juni 2022 Update: Traffic Light Coalition Agreement On November 24, the SPD, the Greens and FDP concluded their coalition talks. The party membership of the three parties have yet to approve the Coalition Agreement. Members of the Green party can vote on the Coalition Agreement and the proposals for personnel in the ten days following 24 November 2021. Kategorien: Tax & Legal NewsSchlagwörter: Income Tax Act, Business taxation, coali ...
13. August 2021 Update: OECD reaches agreement on international tax reform On 1 July 2021, the OECD reached broad agreement on key points for a fair taxation: 130 countries and jurisdictions have joined a new two-pillar plan to reform international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate. Kategorien: From EuropeSchlagwörter: Pillar One, Pillar Two, international ta ...