Suchergebnisse für: `roll-over-relief` (9 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. 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 ...
8. 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 ...
9. 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