Suchergebnisse für: `new-shares` (12 gefunden)

  1. 29. November 2017

    Immediate taxation on transfer of a foreign branch is not pr ...

    In a decision published on 23 November 2017 the European Court of Justice (“ECJ”) again considered the question on the taxation of the transfer of assets of a foreign branch in exchange for new shares. The question was referred to it by the Administrative Court of Helsinki in Finland. The ECJ held that the taxpayer must be given the choice between an immediate charge to tax and a deferred payment of tax.

    Kategorien: From Europe, European Court of Justice
    Schlagwörter: Capital gains taxation, EU Law, Foreign ...
  11. 18. Juli 2025

    Trade tax attribution of profit from the sale of shares in t ...

    The profit from the sale of a share in the upper-tier partnership as prescribed in Section 7 sentence 2 no. 2 Trade Tax Act is not to be allocated to the hidden reserves of the upper-tier partnership and the hidden reserves of the lower-tier partnership. It is rather a single and uniform sales transaction at the level of the upper-tier partnership, the Supreme Tax Court said in a most recently published decision.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: hidden reserves, Two-Tier Partnerships

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Björn Viebrock

Björn Viebrock

Partner
Düsseldorf

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