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Schlagwörter: Trade Tax Loss Carry-Forward (2 gefunden)

  1. 24. Oktober 2022

    Trade tax liability of real estate trading partnership not b ...

    The Supreme Tax Court decided that the actual trade tax liability of a real estate trader arises at the earliest with the conclusion of the purchase agreement for a first property. It is only after the completion of the purchase that he is in a position to offer his services on the market.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: Trade Tax Loss Carry-Forward, Real estat ...
  2. 26. August 2016

    No trade tax loss carry-forward with merger of two-tier part ...

    In its decision of 12 May 2016 the Supreme Tax Court held that -in the case of a two-tier partnership structure- the trade tax loss carry-forward of the lower-tier partnership is fully eliminated, if the upper-tier partnership, which holds a 100% -interest in the income and assets of the lower-tier partnership, is merged down-stream and thus ceases to exist. Referring to previous case law, the Court’s reasoning was that the upper-tier partnership, as co-entrepreneur of the lower-tier partnership, was also the holder of the partnership’s trade tax loss-relief.

    Kategorien: Supreme Tax Court cases
    Schlagwörter: downstream merger, trade tax, Two-Tier P ...
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Björn Viebrock

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