12. Februar 2019 Deduction of final branch losses – a change of track? The Lower Tax Court of Hesse, with reference to the ECJ case Bevola und Jens W. Trock, decided that final losses of a foreign (UK) permanent establishment are deductible in Germany. Kategorien: Supreme Tax Court casesSchlagwörter: Final PE losses, foreign branch losses
26. Juni 2018 Tax & Legal News - Issue 4, June 2018 Some of the topics in this issue: Administration amends circular on treaty-shopping rules, Pensions paid abroad subject to limited tax liability, ECJ - Denmark to set-off final losses of foreign EU-branch. Kategorien: Tax & Legal NewsSchlagwörter: Final PE losses, anti-treaty shopping ru ...
20. Juni 2018 ECJ – Refusal to set-off EU-branch losses in Denmark not com ... A Danish company may set off the final losses of its foreign EU-permanent establishment against its own taxable income, provided it can prove that the losses incurred are final and the company has exhausted the possibilities to deduct those losses in that Member State. Kategorien: From EuropeSchlagwörter: Final PE losses, international joint tax ...
06. Juni 2017 No deduction of final branch losses following EU law. Payments made to a purchaser to compensate for a poor economic position following the transfer of an interest in a partnership may not be deducted from the domestic tax base to the extent they are attributable to a foreign branch (i.e. a permanent establishment for tax treaty purposes) of the partnership. In its decision the Supreme Tax Court cited a decision of the European Court of Justice (ECJ) from 2015. Kategorien: Supreme Tax Court casesSchlagwörter: International Tax, EU Law, Final PE loss ...
