Schlagwörter: corporation tax group (3 gefunden)

1. 02. Mai 2025

   Tax group: Management holding partnership as parent company

   In a recently published decision, the Supreme Tax Court held that a commercial activity as stated in Section 14 (1) no. 2 sentence 2 Corporation Tax Act also exists if the controlling partnership acts exclusively as managing holding company. Intra-group services for other additional commercial activities are not required.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: corporation tax group, management holdin ...
2. 06. April 2025

   Corporation tax group and non-typical silent partnership

   An untypical silent partnership in the controlled group company does not generally prevent the recognition of a consolidated tax group for corporation tax purposes. With this current decision, the Supreme Tax Court disagrees with the previous opinion of the tax authorities.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: non-typical silent partnership, corporat ...
3. 01. April 2019

   Non-deductible deemed business expenses not to be derived fr ...

   If a corporation is merged into its parent company, which in turn is a controlled company within a corporation tax group (fiscal unity/“Organschaft”) with a corporation as the controlling company (“Organträger”), the Supreme Tax Court has ruled that no flat-rate deemed business expenses are to be added back to profits under Section 8b (3) sentence 1 of the German Corporation Tax Act (CTA) either at the level of the parent company or at the level of the controlled company, where the said non-deductible flat-rate deemed business expenses are derived from a merger gain.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Upstream merger, merger profit, corporat ...