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 ...
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
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
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
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-resident, 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, Business taxation, coalition ...
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 ...
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, ...
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 ...
24. März 2021 Government draft for the implementation of the Anti-Tax Avoi ... On 24 March 2021, a government draft bill aiming to implement the Anti-Tax Avoidance Directive (ATAD) passed the cabinet (in the following referred to as “Draft”) after lengthy political efforts. Kategorien: LegislationSchlagwörter: ATAD, International Tax
