Suchergebnisse für: `roll-over-relief` (11 gefunden)

1. 16. April 2015

   Roll-over relief provision infringes EU freedom of establish ...

   The ECJ has held the roll-over relief provisions allowing deferral of the tax charge on a capital gain from the sale of business property to infringe the freedom of establishment inasmuch as they require reinvestment of the gain in a replacement asset in Germany.

   Kategorien: From Europe

   Schlagwörter: capital gain, roll-over relief, business ...
2. 31. August 2017

   5-year tax deferral on transfer of roll-over relief provisio ...

   The Supreme Tax Court has upheld the German rule providing for immediate taxation (but with a deferral option) of the transfer of a roll-over provision to be held as a fixed asset of a permanent establishment in another member state.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: roll-over relief provision, tax deferral
3. 22. Mai 2012

   Four-year carry forward for replacement reserve

   The Supreme Tax Court has held that a replacement reserve for assets lost through accident should be carried forward for the same four-year period as allowed by the roll-over relief provisions.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: replacement reserve, roll-over relief pr ...
4. 18. Dezember 2023

   Excess drawings in a two-tier partnership structure

   In a decision published on 14 December 2023 on Section 4 (4a) of the German Income Tax Act (restriction of deductible interest expense in the case of excess drawings), the Supreme Tax Court decided that the rule whereby Section 4 (4a) Income Tax Act (ITA) is to be applied for each business in isolation – a so-called business-related application - also applies to multi-level partnership structures. As a result, the transfer of a rolled-over profit in accordance with Section 6b ITA (roll-over relief) to another legal entity does not lead to a contribution to the transferring legal entity - (i.e. a contribution which would reduce the level of excess drawings) - due to the fact that no contributable asset was involved.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: non-deductible expenses, loan interest, ...
5. 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 News

   Schlagwörter: inheritance tax, roll-over relief provis ...
6. 19. Oktober 2017

   Tax & Legal News - Issue 4, October 2017

   In this issue: PwC Reports, Official pronouncements, Tax Court Cases and From Europe

   Kategorien: Tax & Legal News

   Schlagwörter: Steuern / Tax
7. 12. September 2025

   Federal Government approves Location Promotion Act Bill: Boo ...

   On 10 September 2025, the Federal Cabinet approved a draft bill to promote private investment and the financial centre (Location Promotion Bill). The draft law aims to provide a stronger impetus for private investment. To this end, the framework conditions for private investment should improve, particularly with regard to infrastructure, renewable energies and venture capital. Companies in the financial market sector will be relieved of unnecessary bureaucracy with the elimination of unnecessary auditing, reporting and disclosure requirements.

   Kategorien: Official Pronouncements, Tax & Legal New ...

   Schlagwörter: Investment Reporting, Investmentbranche, ...
8. 24. Oktober 2025

   Roll-over provision under Section 6b of the Income Tax Act ( ...

   In its judgement of 2 July 2025 ( XI R 27/22), the Supreme Tax Court ruled that a roll-over provision created incorrectly in accordance with Section 6b(3) of the Income Tax Act (ITA) must be corrected in accordance with the principles of formal balance sheet consistency.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: roll-over relief provision, Income Tax A ...
9. 12. Februar 2018

   Write-up of shares in GmbH not part of tax-neutral profit tr ...

   The Supreme Tax Court has decided that a gain arising from a share disposal can be rolled-over on a tax-neutral basis under Section 6b Income Tax Act where the privileged asset has been sold to a related entity. However, the Court also ruled that the part of the gain attributable to the write-up of the privileged asset – where the earlier write-down of the shares had reduced the taxable profits -could not be rolled over as a tax-neutral transfer under section 6b of the Income Tax Act.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: limited partnership, roll-over relief, I ...
10. 17. Februar 2022

    Fourth Corona Tax Relief Act - Draft Bill - UPDATE!!

    The German Federal Ministry of Finance has presented the draft bill for a fourth act implementing tax relief measures to address the Corona crisis (Fourth Corona Tax Relief Act) the following tax measures,inter alia, are envisaged:

    Kategorien: Official Pronouncements, Legislation

    Schlagwörter: Coronavirus (COVID-19), Loss relief, Inc ...
11. 18. März 2011

    Common Consolidated Corporate Tax Base (CCCTB)

    The European Commission has published a proposed CCCBT directive to allow groups active in more than one member state to opt for taxation on a single, consolidated tax base to be allocated over member states on a set formula. Assessment and collection would be by each member state under its own rules and at its own rates.

    Kategorien: From Europe

    Schlagwörter: CCCTB, EU tax consolidation