Schlagwörter: dividend exemption (3 gefunden)

1. 01. Dezember 2021

   Dividend exemption under double tax treaty or abuse of legal ...

   The distribution of profits by a Luxembourg subsidiary (in the legal form of a SARL) to its German parent company (a partnership limited by shares – KGaA) may be an abuse of legal forms where the KGaA provided SARL with a loan and shortly thereafter waived repayment, thereby putting SARL in a position to actually make the profit distribution. Even more when the losses arising from the impairment of the value of SARL because of the distribution are to be used by the shareholders in a tax-effective manner.

   Kategorien: Tax Court

   Schlagwörter: dividend exemption, abuse of legal forms ...
2. 29. Januar 2019

   Trade tax: Dividend income exemption in case of double resid ...

   According to the Lower Tax Court of Hesse, the dividend income exemption for trade tax on qualifying shareholdings is also available for distributions of companies of foreign legal form - provided the foreign company is comparable to a German corporation, has its place of management and thus a permanent establishment in Germany.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: dividend exemption, trade tax exemption, ...
3. 05. Januar 2011

   Intercorporate dividends from Norway confirmed as tax-free

   The finance ministry has confirmed its interpretation of the Norwegian DTT to the effect that dividends received by a German company on a holding of 25% or more are free of German taxation.

   Kategorien: Official Pronouncements

   Schlagwörter: double tax treaty, Intercorporate divide ...