11. Juni 2015 5% non-deductible deemed expense for foreign dividends can i ... An ECJ advocate general has suggested the court hold that the 5% effectively connected expense add-back for foreign dividends infringes a company’s freedom of establishment if an otherwise comparable domestic company could avoid the add-back by joining a tax group. Kategorien: From EuropeSchlagwörter: foreign dividend, tax group, directly co ...
07. November 2013 Denial of corporation tax credit for foreign dividend justif ... An ECJ advocate general has suggested the court recognise a restriction on the free movement of capital from the differing treatment of the corporation tax underlying domestic and foreign dividends, but hold it to be justified in the interests of maintaining the internationally agreed balance of taxing rights. Kategorien: From EuropeSchlagwörter: free movement of capital, foreign divide ...
10. Juli 2013 No trade tax add-back for foreign dividends in 2001 The Supreme Tax Court has held that the provision in the Trade Tax Act requiring that foreign dividends on shareholdings of up to 10% be charged to tax if received in 2001 is contrary to European law and must be disapplied for that year. Kategorien: Supreme Tax Court casesSchlagwörter: add-back, foreign dividend, trade tax
30. Juni 2011 Maximum imputation credit for foreign tax is amount paid The ECJ has held that the foreign tax imputation credit on a dividend received from abroad is the lower of the corporation tax shown to have been paid abroad and the income tax due on the dividend by recipient. Kategorien: From EuropeSchlagwörter: Meilicke, imputation, foreign dividend, ...
