Suchergebnisse für: `option` (1609 gefunden)

1. 28. März 2013

   Supreme Tax Court ruling on option premium applies to hedges ...

   The finance ministry has decreed that a Supreme Tax Court ruling that an option premium is expense on the decision not to exercise the option applies to hedges, but not to speculations.

   Kategorien: Official Pronouncements

   Schlagwörter: hedge, option premium, speculation, forw ...
2. 29. Mai 2013

   Option premium not part of sale proceeds

   The Supreme Tax Court has held that the premium received by the seller of shares for the grant of an option to the buyer is not tax-free in the hands of a company as part of the proceeds of sale.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: option premium, sale proceeds
3. 20. Oktober 2017

   VAT – Supply of goods – Finance lease with option to purchas ...

   On 4 October 2017 the European Court of Justice decided that a finance lease with an option to purchase should be qualified as a “supply of goods” where the exercise the option appears to be the only economically rational choice that the lessee could make at the appropriate time. As a result the whole of the VAT becomes due when the object to be leased is handed over.

   Kategorien: From Europe, European Court of Justice

   Schlagwörter: car leasing, VAT, Supply of goods, Finan ...
4. 24. Oktober 2013

   Option for VAT on sale of real estate

   The finance ministry has accepted an option for VAT on the sale of a business property expressly agreed only for the event that the view of the parties of the transaction as a (VAT-free) sale of an entire business should prove to be unfounded.

   Kategorien: Official Pronouncements

   Schlagwörter: option for VAT, sale of real estate, ent ...
5. 09. Januar 2011

   No income limit on option for full tax liability of EU resid ...

   The Supreme Tax Court has confirmed that the maximum foreign income limit for the option to treat a non-resident spouse as taxable does not apply within the EU.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Option, full tax liability, tax option, ...
6. 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 cases

   Schlagwörter: exercise, option grant, stock options, f ...
7. 30. Januar 2013

   Stock option benefit realised on disposal

   The Supreme Tax Court has held that the benefit from stock options sold is realised on the date of disposal and is to be based on their value at that point in time.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: stock options
8. 30. Dezember 2015

   No deduction for knock-out option losses

   The Supreme Tax Court has held that lapsed options based on market rate movements rather than on a conscious decision by the taxpayer are not deductible from investment income.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Option, investment income, knock-out
9. 08. März 2023

   Taxation of stock options in the event of change of residenc ...

   Concerning the taxation of stock options the Supreme Tax Court decided that the question of residency is not to be answered by looking at the year in which the benefit was received (which was the year in dispute), but rather at the time of the plaintiff's residency abroad in the period between the grant of the options and the date on which the option could be exercised for the first time.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: residence, stock options
10. 27. März 2014

    Tonnage tax option does not exclude partner’s earnings prior ...

    The Supreme Tax Court has held that the exercise of the option for tonnage tax on the profits of a ship sailing in international waters does not preclude regular taxation on the earnings of a partner from services to the partnership prior to the ship’s commissioning.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: tonnage tax
11. 16. Februar 2024

    Federal States Supreme Tax Authorities Identical Decrees: Ap ...

    In identical decrees issued by the Supreme Tax Authorities of the Federal States, the tax authorities comment upon the judgment of the Supreme Tax Court of 26 July 2022 (II R 25/20) and upon the underlying view that the option relief under Section 13a (10) Inheritance Tax and Gift Tax Act (or Section 13a (8) IHTA old version) can be exercised separately for each economic unit transferred. This applies to all open cases.

    Kategorien: Official Pronouncements

    Schlagwörter: family business, inheritance and gift ta ...
12. 06. August 2024

    Update: ECJ confirms option for full income tax assessment t ...

    The European Court of Justice decided that the refusal of the option for full income tax assessment for German citizens living in Switzerland contravenes the principle of non-discrimination contained in the Agreement for the Free Movement of Persons between the EU and Switzerland.

    Kategorien: European Court of Justice

    Schlagwörter: free movement of workers, tax assessment
13. 24. Februar 2011

    Receipt for repurchase obligation to be deferred until expir ...

    The Supreme Tax Court has held that the additional proceeds from the sale of goods with an option for the buyer to require repurchase shall be deferred until the option expires.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: Steuern / Tax
14. 13. Oktober 2011

    Buy-back commitment in motor trade to be taken up as separat ...

    The finance ministry has decreed that a motor vehicle dealer who has undertaken to buy back a vehicle from a customer must take up the option premium as a liability to be released on expiry of the option.

    Kategorien: Official Pronouncements

    Schlagwörter: motor trade, buy-back, put option
15. 21. Mai 2013

    Employee option in valuing staff purchases

    The finance ministry has instructed tax offices to follow the Supreme Tax Court in allowing employees to value their benefit from subsidised staff purchases under the general rules for benefits in kind, if more favourable.

    Kategorien: Official Pronouncements

    Schlagwörter: benefit in kind, staff purchases
16. 28. September 2011

    No income from stock option exercise if disposal of shares l ...

    The Supreme Tax Court has held that the issue of shares at a reduced price is not a taxable benefit if the acquirer is legally unable to dispose of them.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: exercise, disposal, stock options
17. 13. Mai 2025

    Tonnage tax option only available if intended to operate the ...

    In a most recent decision, the Supreme Tax Court upheld the tax office’s refusal to allow a partnership to compute its income on tonnage tax principles – as these presuppose an intent to operate the ship in international waters in the long term. Furthermore, the court decided that the determination of profits by tonnage for a subsequent year requires that specific requirements laid down in section 5a (1) sentence 1 and (2) of the Income Tax Act as to time and deadlines are met.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: tonnage tax
18. 23. Juni 2023

    ECJ: Partial trade tax addback of portfolio dividends in 200 ...

    The trade tax addback of foreign portfolio dividends in the year 2001 is in line with the EU provision on the free movement of capital in Article 63 TFEU (formerly: Article 56 TEC). This was decided by the European Court of Justice in an answer to a preliminary request submitted by the Supreme Tax Court.

    Kategorien: European Court of Justice

    Schlagwörter: portfolio dividend, trade tax addback
19. 10. November 2021

    Foreign tax credit possible even if several options to reduc ...

    The regional tax court of Rhineland-Palatinate had to decide whether, in the case of a right to choose between two methods of reducing foreign withholding tax, the taxpayer must ensure that foreign taxes are credited in as small an amount as possible. The regional tax court is of the opinion that it is at the discretion of the taxpayer if and how to use the option to which he is entitled and that this does not have an adverse impact on the general possibility of a foreign tax credit against his German income tax liability.

    Kategorien: Tax Court

    Schlagwörter: foreign tax credit, foreign withholding ...
20. 06. März 2015

    Option for non-resident to be taxed as a resident for only p ...

    An ECJ advocate general has suggested the court allow a non-resident meeting the requirements for taxation as a resident for only part of the year to opt for taxation as a resident for that period.

    Kategorien: From Europe

    Schlagwörter: Option, non-residents
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