Suchergebnisse für: `organschaft` (148 gefunden)

  7. 11. September 2013

    Organschaft parent need not be active business until subsidi ...

    The Supreme Tax Court has held that an Organschaft parent must be an active business by the effective date of the first profit surrender, i.e. the first year end of the subsidiary. It also held that the provision allowing profit pooling agreements with formally inadequate loss subvention provisions to be corrected by December 31, 2014 applies to all agreements existing on February 26, 2013 regardless of the nature of the inadequacy.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: Organschaft, Active business, parent, pr ...
  12. 10. November 2017

    Tax Consolidation Groups (“Organschaft”) for income tax purp ...

    According to a decision of the Supreme Tax Court published on 9 November 2017 a profit pooling agreement will not be recognised for tax purposes where the compensation agreement with the external shareholder contains both the right to a variable compensation payment calculated on the basis of the profits of the subsidiary/controlled company/"Organgesellschaft" (“subsidiary”) and a fixed amount.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: Organschaft, Corporation tax, compensati ...
  13. 23. Januar 2013

    Bill for Revision and Simplification of Corporate Taxation a ...

    A partial compromise was reached by a mediation committee of the two chambers of Parliament leading to a modified Bill for the Revision and Simplification of Corporate Taxation and of the Tax Law on Travel Cost and to acceptance of a modest increase in the basic personal allowance for income tax. The Bundestag has now passed both bills and forwarded them to the Bundesrat for confirmation at its next session, due to be held on February 1, 2013.

    Kategorien: PwC Reports
    Schlagwörter: profit pooling agreement, loss carry-bac ...
  18. 01. Dezember 2020

    Retroactive financial integration in case of change in share ...

    A continuous and retroactive financial integration is also possible where a change in shareholder takes place during the year. The Lower Tax Court of Duesseldorf held that a fiscal unity or tax consolidation group for corporation income tax may be established already for the whole year in which the exchange of shares took place. In its judgement the court disagrees with the tax authorities’ official opinion on this issue. The Supreme Tax Court is now in charge and must finally decide the dispute.

    Kategorien: Tax Court
    Schlagwörter: retroactive change, change in shareholde ...
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