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 JusticeSchlagwörter: Capital gains taxation, EU Law, Foreign ...
13. Januar 2016 Consideration in kind valued on day of contract fulfilment The Supreme Tax Court has held that the capital gain on the exchange of shares is realised when the shares are delivered but should be based on the value of the shares received when received. Kategorien: Supreme Tax Court casesSchlagwörter: contribution in kind, consideration in k ...
21. März 2013 Asset transfer costs from sidestream and downstream mergers ... The Supreme Tax Court has held that the exclusion of merger cost as part of the non-taxable profits and losses on merger also applies to indirect shareholdings. Kategorien: Supreme Tax Court casesSchlagwörter: downstream merger, merger, sidestream me ...
08. August 2016 Negative Goodwill in the case of a contribution The Federal Supreme Tax Court upheld a decision of the Münster Tax Court and held: Kategorien: Supreme Tax Court casesSchlagwörter: contribution, Reorganisation Tax Act, Ne ...
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 ...
27. Januar 2011 Share exchange on merger at nominal value releases hidden re ... The Supreme Tax Court has held that a share exchange at nominal value leading to a transfer of hidden reserves abroad triggers a taxable capital gain for the transferring shareholder. Kategorien: Supreme Tax Court casesSchlagwörter: capital gain, hidden reserves, Share exc ...
25. April 2014 Shares sold to be specifically identified by serial numbers The Supreme Tax Court has held that shares sold from a mixed holding should be identified from their serial numbers. GmbH shares sold should be identifiable from the contract. Kategorien: Supreme Tax Court casesSchlagwörter: capital gain, shares sold, serial number ...
05. Januar 2011 No stock option expense before exercise The Supreme Tax Court has held that a company incurred no expense in the issue of free-of-charge stock options to its staff. Kategorien: Supreme Tax Court casesSchlagwörter: stock option, exercise, option grant, fr ...
31. Oktober 2016 Deadline for the filing of an application for recording at t ... The Supreme Tax Court held, in a decision published on 27 October 2016, that: Kategorien: Supreme Tax Court casesSchlagwörter: Tax Reorganisations Act, Tax Book Values ...
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
