Schlagwörter: limited partnership (6 gefunden)

1. 16. Juli 2020

   Shareholding in corporation as a Special Business Asset II

   The Supreme Tax Court has ruled that for the purposes of considering the allocation of a partner's share in a GmbH to the Special Business Assets II of his partnership interest, regard must be had not only to the business relationship of the GmbH with the partnership – but also to whether the GmbH has a substantial business operation of its own.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: limited partnership, special business as ...
2. 15. Februar 2019

   Does a letterbox company have legal capacity?

   In a case involving a charge to real estate transfer tax (RETT), the Supreme Tax Court granted the taxpayer interim relief in the form of a suspension from execution (i.e. a delayed tax payment), as the question arose as to whether one of the parties to the transaction, a letterbox company, had legal capacity.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: limited partnership, Letter-Box Companie ...
3. 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 ...
4. 17. März 2017

   No extended trade tax deduction on the disposal of an intere ...

   Profits arising from the sale of an interest in a partnership are not to be included in the extended trade tax deduction for real estate enterprises.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: limited partnership, Extended deduction ...
5. 16. März 2017

   Interest paid by foreign partner deductible also in case of ...

   In a decision published in March 2017 the Supreme Tax Court held that - in the case of a two-tier partnership structure – the interest expense of the Dutch partner holding only an indirect share in a German limited partnership is nevertheless tax deductible when computing his limited German tax liability resulting from his investment in the German partnership.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: limited partnership, Two-Tier Partnershi ...
6. 10. August 2011

   Foreign limited partnership does not shield non-trading inco ...

   The Supreme Tax Court has held that rental income earned through a Hungarian partnership is not automatically exempt as the income from a foreign permanent establishment, merely because the partnership was taxed locally as a corporation, or because the income would have been treated as trading income had it been earned through a German partnership.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: rental income, limited partnership