Schlagwörter: beneficial owner (3 gefunden)

1. 28. Februar 2019

   ECJ provides guidance on beneficial ownership and abuse of r ...

   On 26 February 2019, the ECJ issued its judgements in the joined cases T Denmark and Y Denmark -v- the Danish Ministry of Taxation (C-116/16 and C-117/16) and N Luxembourg 1, X Denamrk A/S, C Danmark I and Z Denmark ApS -v- the Danish Ministry of Taxation ( C115/16. C-118/16, C-119/16 and C-299/16).

   Kategorien: European Court of Justice

   Schlagwörter: beneficial owner, ECJ, Parent-Subsidiary ...
2. 16. November 2016

   Schematic loan and return of securities

   The Finance Ministry has decreed on a Supreme Tax Court judgment regarding securities lending schemes and provides some guidance as to when a transfer of economic ownership of the securities takes place.

   Kategorien: Official Pronouncements

   Schlagwörter: economic owner, beneficial owner, securi ...
3. 05. Januar 2011

   No requalification of royalty income of US partner to busine ...

   The Supreme Tax Court has held that the treaty attribution of the royalty income charged by a US partner is to his US business. Accordingly, it is not taxable in Germany as partnership profits.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: treaty override, Royalty income, requali ...