23. Mai 2022 ECJ and VAT: No fixed establishment through subsidiary provi ... In a recent judgment the European Court of Justice (ECJ) held that a German company does not maintain a fixed establishment through its Romanian subsidiary where the latter actively promoted the products of the German company in Romania based on marketing, advertising and regulatory strategies established and developed by the German parent. Kategorien: European Court of JusticeSchlagwörter: permanent establishment, marketing subsi ...
08. Juli 2021 VAT: No permanent establishment in case of property rental The European Court of Justice (ECJ) ruled that the reverse charge is applicable to the leasing of real property located in Austria because the Jersey based lessor, in lieu of own local staff to perform services relating to the letting, does not have a permanent establishment (fixed place of business) in Austria. Kategorien: European Court of JusticeSchlagwörter: reverse charge, permanent establishment, ...
03. Juni 2019 Locker can constitute a fixed place of business for double t ... The Supreme Tax Court refused to overturn the tax court’s decision to refuse leave to appeal, agreeing with the lower court that a locker can constitute a fixed place of business within the meaning of Article XI Paragraph 1 of the German/British double tax treaty. Kategorien: Supreme Tax Court casesSchlagwörter: double tax treaty, permanent establishme ...
01. Januar 2017 Administration publishes regulations on branch profits On December 22, 2016 the finance ministry has finally published its detailed administrative principles on the allocation of profits between a business and its foreign branches. Kategorien: Official PronouncementsSchlagwörter: permanent establishment, branch, AOA, ad ...
17. Dezember 2015 Foreign branch loss recapture provision confirmed The ECJ has confirmed a German provision for the recapture of foreign branch losses previously deducted on sale of the foreign permanent establishment. Kategorien: From EuropeSchlagwörter: permanent establishment, Foreign branch, ...
05. September 2013 Draft ordinance on permanent establishment profits The finance ministry has published a draft of its ordinance on permanent establishment profits following the authorised OECD approach. Kategorien: PwC ReportsSchlagwörter: permanent establishment, ordinance, AOA, ...
21. März 2013 Old corporation tax rate on German branch income of non-EU c ... The Supreme Tax Court has held that the corporation tax rate on the permanent establishment income of non-EU foreign companies under the old, pre-2001 system was acceptable under community law and the double tax treaty. Kategorien: Supreme Tax Court casesSchlagwörter: permanent establishment, branch, imputat ...
