Suchergebnisse für: `unsecured-group-loan` (3 gefunden)

1. 09. April 2021

   Successful constitutional complaint against income correctio ...

   The German Constitutional Court overturned a 2019 judgment of the Supreme Tax Court regarding the erstwhile change in its case law on the issue of the income correction with respect to an unsecured group loan because the tax court failed to submit the facts of the case to the European Court of Justice (ECJ) for final clarification and thus violated the complainant's right to the lawful judge under Article 101(1) of the Constitutional Statute.

   Kategorien: Constitutional Court

   Schlagwörter: allocation of taxing rights, income corr ...
2. 17. Mai 2019

   Newsflash: Supreme Tax Court changes its case law regarding ...

   According to the Supreme Tax Court in its ruling of 27 February 2019, published on 15 May 2019, and contrary to its previous case law, Article 9 (1) of the OECD Model Tax Convention, does not prohibit an income adjustment under domestic transfer pricing rules, where the write-off of an unsecured group loan is not recognised as a deduction from taxable profits.

   Kategorien: Tax & Legal Newsflash

   Schlagwörter: Steuern / Tax
3. 01. Juli 2022

   Income adjustment pursuant to Section 1 (1) FTA vis-à-vis a ...

   Following a referral from the Federal Constitutional Court, the Supreme Tax Court has again had to rule on the income adjustment pursuant to Section 1 (1) Foreign Taxes Act vis-à-vis the write-down of an unsecured loan receivable issued within a group

   Kategorien: Supreme Tax Court cases, Constitutional ...

   Schlagwörter: income adjustment, International Tax, un ...